By Denise Williams | News & Views
*If you attended the AACVPR Annual Meeting session on upcoming Medicare changes, do you have all the information you need for the upcoming year? NOT QUITE: that presentation was a teaser of potential, but not final, revisions for 2023. “It’s helpful to know what’s proposed,” says Karen Lui, BSN, MS, MAACVPR, “but it’s necessary to know what’s final.” The fate of virtual delivery of cardiac and pulmonary rehabilitation is a prime example.
*If you spent the past 12 months trying to get a handle on last year’s updates, do you finally have all the answers to the questions that have popped up since then? NOT NECESSARILY: Lui and Susan Flack, RN, MS, FAACVPR – our resident experts on all things Medicare – are still fielding inquiries, for instance, about the pulmonary rehabilitation changes introduced in 2021 for the current calendar year.
*And if you’ve asked around and cobbled together information from different sources to fill in gaps in your understanding of certain policies, is your cardiac or pulmonary rehab program in compliance? PROBABLY NOT: there’s a good deal of misinformation circulating, Flack and Lui observe, along with accurate information that is widely misinterpreted. Flack says pointedly, “If you don’t know first-hand, with 100% confidence, that you are billing correctly, that you are getting reimbursed for what you charge, and that you are following the regulations as currently set; or if you’re not confident and don’t have a contact in your organization to help with that, there’s a chance that you’re not compliant.”
‘Virtual’ Ball of Confusion
If that’s the case, our pair agrees that there’s no mystery why. Medicare is confusing! The rules are constantly in flux, changing with each calendar year. Two different sets of regulations govern the cardiopulmonary rehabilitation community – the physician fee schedule and the hospital outpatient prospective payment system. Ambiguous information makes the policies difficult to decipher. And the COVID-19 pandemic adds another layer of complexity with a series of temporary and ad hoc provisions that may or may not end once the public health emergency lapses.
Two major decisions coming out of the Centers for Medicare & Medicaid Services (CMS) for 2023 target virtual direct supervision and virtual delivery of rehab. CR and PR programs were afforded the leeway to use these flexibilities in the context of the COVID-19 crisis, but the final rules differ between programs in the hospital outpatient setting versus in the physician office setting.
Plugging into Reliable Information Sources
Considering just the example of virtual CR and PR, there’s no wonder it’s so hard to keep up with the Medicare ‘machine,’ Flack and Lui concede. But, they cannot emphasize enough that doing so is incredibly important. Even the smallest and seemingly most trivial of adjustments – such as knowing which CPT code to bill – can have a significant positive or negative impact on cardiac and pulmonary rehab programs, which balance on a fine line between being on the plus or minus side financially. “This is important information,” Lui reiterates. “We all need to know the final rules for CMS for calendar year 2023 in order to properly deliver, bill, code, collect co-pays and provide our services in the most appropriate and effective ways.” Programs may lack the time or ability to really dig into what they need to know for the upcoming year. It makes sense, then, to get that information from trusted and knowledgeable advocates who are invested in the cardiopulmonary rehab discipline, a proverbial ‘small fish in a big pond’ among healthcare services tracked by hospitals.
For these reasons and more, Lui and Flack staged a live AACVPR webcast on December 6. The presentation offered a refresher of last year’s pulmonary rehab code and diagnoses changes and provided a run-down of what to expect for 2023, while discussing how the policies track with AACVPR’s advocacy agenda.
The association is committed to pursuing a Congressional path for virtual delivery to supplement center-based CR and PR programs. In addition, Lui says AACVPR will promote HR 1956/S.1986, which will secure the ability for non-physician practitioners to independently order CR and PR services. Work will also continue on behalf of what Lui views as one of the most important pieces of legislation AACVPR has ever promoted. The campaign will press on, she says, to pass the Sustaining Outpatient Services (SOS) Act (HR 3348), which will secure the hospital payment rate for our services despite the program’s physical location.
“Our advocacy message is so important to our services,” Lui asserts, adding that it’s also “exceedingly important that cardiac and pulmonary rehab practitioners be familiar with all aspects of our services.” Her webinar with co-presenter Flack was an invitation to get caught up on both. For AACVPR members who weren't able to tune into the livestream of "2003 Medicare Regulations & Legislative Priorities -- A Look Ahead," a recording is available at no cost.