As health care regulations continue to rapidly change, alternative payment models are becoming more common across health care settings. Successfully demonstrating the quality and efficiency of your services is now more important than ever. However, many organizations are still struggling to adapt to this change.
In a recent webinar, Heather Smith, PT, MPH and Matt Elrod, PT, DPT, MEd from the American Physical Therapy Association (APTA) outlined how therapists can use APTA’s Physical Therapy Outcomes Registry and data to optimize clinical performance. The webinar is now available to watch on-demand. In this new blog, Heather and Matt answer some of the most popular questions asked by webinar attendees.
Q: We have difficulty gathering outcomes data at the end of an episode of care due to a very high level of self-discharge. This is a problem on many levels, but how will this impact payment?
Heather: First of all, this challenge is not unique to anybody, and we hear it consistently. We recently looked at the functional limitations reporting data required by Medicare, and only 30 percent of the cases in the 2014 sample had discharge data. So, it’s evident getting that second data points a huge challenge. I would encourage therapists to collect data not just at intake and discharge but also at other key points throughout the episode of care.
Matt: Every organization needs to identify their best practices for gathering outcomes data to ensure payment. Some organizations take it to an extreme and collect the outcome measure every time the patient comes in. Other organizations use technology — such as an email at the close of care — that includes a simple assessment for the patient to take. Other organizations call patients individually to say they appreciated working with them and ask why they opted to end their care.
As therapy patients near the end of their care, therapists should complete the following best practices:
- Have direct conversations with patients to remind them they’re almost done with care
- Reiterate that patients need to come in one more time
- Explain to patients why finishing their plan of care of important
These best practices support quality improvement. With this data, you can identify gaps, and more importantly, you can also analyze this data to better understand why those gaps are present. For example, you may not identify a big problem, but you could discover a more concentrated problem affecting a specific patient demographic or patient population that tends to not complete their care. Standardizing, collecting, and analyzing your practice’s data helps you better understand your organization and pointedly address specific problems.
Q: How can a physical therapy department ensure adequate data collection and documentation to make use of the Registry effective?
Matt: First, you should understand what data elements you need to capture and determine if you’re already collecting that information. The Registry’s data set is in the public domain, and the specifications and standards of its individualized data elements are available at www.LOINC.org and searching for “physical therapy outcomes registry.” You can also reach out to us at APTA directly for that information by emailing email@example.com. From our experience in working with various organizations, we’ve seen that most facilities are collecting these items already — they might just not be collecting it in a similar way. The next step is seeing how we can get everyone on the same page.
We are also working with electronic health record (EHR) vendors to have them standardize this information. It’s also important to understand that when you modify everything just to suit your needs, you are changing a lot of things. These modifications can have ramifications and allow you to only look at your data set as one to one instead of one to many.
Q: When do you think regulations will mandate quality measures reporting for physical therapy?
Heather: In post-acute care settings, therapists are already required to contribute to a standardized data collection tool. This tool differs according to setting:
- Inpatient rehab facilities collect the IRF-PAI, which includes the FIM
- Skilled nursing has the MDS
- Home health has the OASIS
The data collected in these three forms is used for quality reporting. That quality reporting is done at the facility level so that the facility gets the quality measure on improvement in function or improvement with activities in daily living. Therapists may not feel that this directly impacts them, but this quality measure reporting is a Medicare requirement. This is how therapists in those settings are contributing.
In outpatient settings, Medicare formerly had a quality reporting program under the Part B Fee-for-Service Payments called the Physician Quality Reporting System (PQRS). That program was tied to a 2 percent penalty if organizations did not appropriately report. That program ended formally at the end of 2016. Now there is a new data reporting program in place called the Merit-based Incentive Payment System (MIPS). Physical therapists, occupational therapists, speech-language pathologists, and several other non-physician providers were not included in the program in 2017 or 2018, but CMS has the authority to add these providers in 2019. We won’t know for sure what CMS will do until we see the proposed rule at the beginning of summer.
If you are a therapist in outpatient settings, it’s imperative that you keep an eye on the proposed rule to determine if it includes this change — especially because MIPS has much higher penalties, and the program reporting is much more complex. The good news is that the Registry already reports into MIPS for Medicare, and APTA is working with many of the physician groups who already report into the program.
Q: It seems like standardizing terminology, developing the necessary clinical practice guidelines, agreeing on data collection methods and reporting, and compiling the Registry data will take a very long time. Do you think physical therapy organizations will be on track to lead this initiative? Or will we be forced to react to regulations that “beat us to the punch?”
Matt: We are actively working to better understand data standards and how they should be communicated. Physical therapy is at the forefront of the interoperability conversation, and APTA is leading that conversation. Other professional organizations look to us for best practices. We built the Registry to incorporate what we as a profession determine are our data standards. This includes what our common denominators are and what’s important to our practice. Sharing this information within the physical therapy profession is incredibly valuable, and the value of this information extends beyond our industry. These data elements are also the exact same data elements that need to be shared with physicians, other therapists, and patients.
Heather: We’re also participating in collaborative discussions around how physical therapy’s clinical practice guidelines (CPGs) may work for other health care providers. We’re thinking beyond physical therapy to determine how our measures align with other measures in the health care system. These critical conversations continue to move our profession forward.
Q: Is the physical therapy industry at risk of allowing private payers to define outcomes reporting standards based on CMS taking a step back in the future?
Heather: I don’t think commercial payers are looking to set these standards, yet they also want to know what they should be doing. Private payers are looking to us to help them navigate these waters, and this puts the profession in a great position. It’s a huge opportunity for us to say, “Yes — this is a measure that’s representative of our value, so please look at this as an outcome measure that’s appropriate for this patient population.” With APTA’s registry, our ability to develop measures, and our ability to identify the best measures, physical therapists are well positioned to help private payers better understand outcomes reporting.
Matt: If we don’t have these conversations with private payers and Medicare, someone else will do it for us. We are in a unique position to represent the entire physical therapy profession with a clear, unified voice.
About the Authors:
Heather Smith, PT, MPH is director of quality for APTA. In her current role, she coordinates quality initiatives for the association and develops and implements key member resources related to quality for programs under Medicare that impact physical therapists, including the respective post-acute care quality reporting programs (QRPs), the physician quality reporting system (PQRS), and the functional limitation reporting (FLR) requirements for therapy services under Medicare. She also serves as a consultant for the Physical Therapy Outcomes Registry.
Matt Elrod, PT, DPT, MEd is lead specialist in the Practice Department of the American Physical Therapy Association. In this position he provides consultation to other APTA departments and members, is a liaison to various external organizations, and contributes to policy development to advance the practice of physical therapy. This includes developing member resources in evidence-based practice, ICD-10 transition, telehealth, adoption of electronic health records, and integration of the Physical Therapy Outcomes Registry. He has more than 20 years of experience working in the physical therapy profession. He earned a physical therapy degree from the Medical University of South Carolina, a Doctor of Physical Therapy degree from Marymount University, and a Master of Education from The Citadel in exercise physiology. He is a board-certified clinical specialist in neurologic physical therapy. He previously worked as a physical therapist in acute care, acute rehabilitation, and was an owner of an outpatient private practice.