The Center for Medicare and Medicaid Services (CMS) has published a "Proposed Decision Memo for Pulmonary Rehabilitation that can be viewed in full by the following website link: (https://www.cms.hhs.gov/mcd/viewdraftdecisionmemo.asp?id=199). The bottom line is the CMS does not propose to make any
"The Centers for Medicare and Medicaid Services (CMS) proposes that the respiratory therapy services identified in the Comprehensive Outpatient Rehabilitation Facility (CORF) as defined in 42 CFR [section]410.100(e)(1) to (2)(vi) are reasonable and necessary in chronic obstructive pulmonary diseases (COPD) in patients with GOLD classification II or III (moderate or severe) when furnished under a written plan of treatment that considers all respiratory therapy services.
CMS proposes that since the Social Security Act does not expressly define a comprehensive Pulmonary Rehabilitation Program as a part B benefit, and that the evidence is not adequate to draw conclusions on the benefit of individual components of pulmonary rehabilitation, we are not making any proposed national coverage determinations about these services at this time.
We are requesting public comments on this proposed determination pursuant to [section] 1862(l) of the Social Security Act. We are particularly interested in comments that include input on the frequency and duration of the respiratory therapy services identified in 42 CFR [section] 410.100(e)(1) to (2)(vi). After considering the public comments and any additional evidence we will make a final determination and issue a final decision memorandum."
If you wish to make comments, please go to the website and give input.
As a result of this decision, I would strongly urge each and every one of you to review the pulmonary rehabilitation coverage in your state (to identify if you have a local coverage determination for pulmonary rehabilitation go to (http://www.cms.hhs.gov/med/index_lmrp_bystate.asp) and type in pulmonary rehabilitation in the search engine on that site. If you do not have coverage for pulmonary rehabilitation, you should review your physical therapy local coverage, especially for diagnoses of pulmonary dysfunction as covered diagnoses. If you do not have coverage for pulmonary rehabilitation, I would recommend contacting the reimbursement chair for your state (if you do not know who it is you can always contact Rhea Cohn at the APTA Reimbursement Department) and discuss ways to contact your Medicare carrier in your state to discuss coverage.
This February at the Combined Sections Program the CV & P Section is having 2 joint programs with the 2 external organizations we have established liaisons: Preventive Cardiovascular Nursing Association (PCNA) and American Thoracic Society (ATS). The programs are "The Changing Face of Long Term Oxygen Therapy" presented by Richard Casaburi, MD, PhD and "Women and Heart Disease Across the Lifespan from Pre- to Postmenopause" presented by Kathy Berra, MSN, RN, APN. The CV&P Section Executive Board will be meeting with these representatives at this meeting to discuss other collaborative efforts in the future.
The State Government Affairs Meeting is scheduled for this September, and I will be representing the Section at this meeting. This is a great time to not only learn about the legislative issues across the country and current professional issues, but to network with these other legislative representatives so that they know about Cardiovascular and Pulmonary legislative issues. Some states are having legislative bills proposed to license Exercise Physiologists at this time, including Massachusetts and possibly North Carolina. If you know of any issues similar to this in your state, or other issues that you wish to discuss, please contact me via email.
Lastly, although there are 2 dedicated committee members who have been reviewing the literature for pulmonary and cardiovascular articles applicable to our members or applicable to legislative issues, we are always looking for volunteers who would assist us in reviewing the articles that have been identified, or perusing the literature for other specific topics related to chronic cardiovascular or pulmonary diseases. Please contact me if interested.
Respectfully submitted,
Ellen Hillegass, EdD, PT, CCS, FAACVPR
Chair
ezhillegass@mindspring.com