CT-Anonymous

I would like to give comment regarding the proposed wage index for FY 2012. It has been reported for a number of years that there exists "case mix creep". Yes as clinicians became more proficient and understood the tool more case mixes increased. It is true that this did not represent the patients having changed but that the clinicians were now accurately capturing the data and were reflecting the patients clinical picture. There has been an increase in the past several years in therapy utilization. Some of that has to do at least in my area with the availability of qualified therapists. It has only been in recent years that we have had adequate therapists physical and occupational to meet patient needs for intensity of therapy visits. I see from the analysis that there is a rise in the use of PTA and COTA for therapy and that it is cause for concern. Home Health agencies are required to supply you with the information about the who is performing visits. It would make sense that agencies using Aides in this capacity could sustain reductions in reimbursement. However for an agency such as the one I work for the use of PTA and COTA is minimal. The current cuts to the case mix and especially as it relates to therapy utilization will force us to reconsider the use of PTA and COTA's to survive. Agencies have been reporting the use of PTA and COTA's. It would make sense that agencies who utilize these disciplines could sustain reductions in reimbursement. Where as those of us who do not use them often should be reimbursed accordingly. If the concern is the use of PTA and COTA then do not create a situation that perpetuates the problem. Additionally as reimbursement is cut further what we see is the agencies who have been more profitable survive while agencies that have smaller margins fail. If gaming is occurring those agencies would be more profitable and more likely to survive significant cuts. Thus preserving those who may be committing abuse.