Part 3 of a 3-part series on the proposed 2019 Medicare physician fee schedule. This installment: there's more to the proposed rule than PTs being required to participate in the Quality Payment Program—including some very good news.

The fact that physical therapists (PTs) could be widely engaged in a value-based payment model in 2019 is definitely the big takeaway from the proposed 2019 physician fee schedule released by the US Centers for Medicare and Medicaid Services. But the sweeping proposal also includes some other significant changes that could affect both PTs and physical therapist assistants (PTAs). Here's a rundown of 3 of the biggest non-Quality Payment Program-related changes included in the proposed rule.

Something to celebrate: the end of functional limitation reporting (FLR).
Criticized by APTA as an undue administrative burden that yields little of value, FLR would finally be put out to pasture if the proposed rule is adopted. In its reasons for eliminating the requirement, CMS described the "general consensus" of commenters responding to a CMS request for ways to reduce administrative burden that FLR was "overly complex and burdensome." The agency estimates that PTs in private practice would have saved between 130,000 and 190,000 hours of administrative work in 2017 had FLR not been in place.

The change is a win for APTA and its members, and the association is mentioned in the proposed rule as a "specialty society" that supplied CMS with data on the inconsistent timing of FLR reporting—another issue that fueled the decision to eliminate the requirement.

Something to be concerned about: is CMS setting the stage for the PTA payment differential?
If enacted as proposed, the rule would establish 2 new therapy modifiers to identify the services furnished in whole or in part by PTAs or occupational therapy assistants (OTAs) beginning. January 1, 2020. The modifiers, mandated by the Bipartisan Budget Act of 2018, would be used in place of the GP and GO modifiers—the ones currently used to identify PT and OT services furnished under an outpatient plan of care—and will pave the way for a planned payment differential that would reimburse services provided by PTAs and OTAs at 85% of the fee schedule beginning in 2022.

Although the modifiers won't officially be in place until 2020, CMS plans on accepting voluntary use of the modifiers next year. CMS also proposes to define “in part” to mean any minute of the outpatient therapy service that is therapeutic in nature and that is provided by the PTA or OTA when acting as an extension of the therapist. The new modifiers would not be applied when a PTA or OTA furnishes non-therapeutic services—such as scheduling appointments, greeting the patient, or preparing the treatment area.

APTA is opposed to the adoption of a payment differential system and will be advocating for changes before the 2022 implementation date.

Something to keep an eye on: CMS may be warming up to broader use of technology.
While it appears that, for now at least, the changes will be limited to physicians and other qualified health professionals who can report evaluation and monitoring services, CMS is proposing that activities such as virtual check-ins, interprofessional internet consultation, and remote evaluation of prerecorded patient information could qualify for some form of payment. APTA is seeking clarification from CMS as to whether any of these services could be furnished and billed by PTs.