AARC Issues Comments on Proposed PR Regulations
August 28, 2009
The proposed regulations for the Medicare pulmonary rehabilitation benefit set to go into effect in January have raised significant concerns among the pulmonary community.
Working closely with fellow groups and organizations, including the American Association of Cardiovascular and Pulmonary Rehabilitation, American College of Chest Physicians, American Thoracic Society, and National Association for Medical Direction of Respiratory Care, the AARC has now formulated its comments.
These are the take home messages being forwarded to the Centers for Medicare and Medicaid Services:
- The proposed payment rate of $15 per one hour increment represents a 78% reduction in payment from the G codes established by CMS in 2002, which call for a rate of $18-$20 per 15 minute increment.
- The proposed recommendation to cover PR only for moderate and severe COPD runs counter to the GOLD guidelines, which recommend PR for moderate, severe, and very severe COPD patients.
- Restricting access to PR to only moderate and severe COPD patients would, in effect, deny coverage to patients with other conditions who currently enjoy access via Local Coverage Determinations (LCDs).
- The proposed limit on the number of billable hours to 36, with one hour of billable service per day, does not reflect standards in the peer review literature and runs counter to CMS policy outlined in the Lung Volume Reduction Surgery LCD, which mandates two hour minimum sessions and up to 60 hours per beneficiary.
The AARC goes on to recommend alternatives for consideration, including:
- Continued use of the current G codes to bill for PR, along with current policy permitting component billing of related services.
- Allow physicians to bill separately when physician work is appropriate and necessary.
- Establish a system that will enable CMS to bundle PR services separately from physician work.
- Include a coding mechanism for an initial intake assessment on patients enrolled in PR programs.
- Reassess equipment provisions, noting PR includes not only a treadmill, oximeter with printer, and one channel ECG monitor, but also exercise bicycles (both upright and recumbent), arm ergometers, exercise bands, Stairmaster-type equipment, emergency cart/resuscitation equipment, and oxygen.
The AARC comments have been issued to CMS in two letters. The first addresses payment provisions for PR under the hospital outpatient PPS update and the second addresses PR provisions in the physician fee schedule.