Occupational therapists want the general systems funk
Specialization is an unfortunate by-product of expansive knowledge. It is challenging to remain abreast of developments in multiple fields and in the busy lives of modern day humans people come to rely on the comprehensive thinking of 'others' while they busy themselves with their specialized thinking.
Few stop to consider whether or not those 'others' to whom great power is ceded for their comprehensive thinking are actually up to the task. Or, if they are up to the task, who is doing the checking to make sure that the use of said power is being delegated for the broader good?
In particular, occupational therapy is a broad field with multiple areas of specialization. As such, practitioners working in geriatric long term care facilities may not be paying much attention to the goings-on for their pediatric school-based colleagues, and vice versa. In a complicated world where specialists struggle to function within their own constricted spheres of operation it is hard to get people to attend to immediately relevant concerns much less concerns that may not seem so immediately relevant.
So when CMS (the governmental entity responsible for the Medicare program) asks for information about creating or updating CPT codes, the immediate response from those in power is to delegate authority to those who have experience with the Medicare program, which is mostly oriented toward care for the elderly. Those specialists come up with recommendations that make local sense for the profit-driven environments in which they work - which is exactly the system that is being proposed.
Lack of comprehensive thinking is evident because the recommendations that make local sense don't even share consistency with the philosophical orientation of the parent organization. Whether one agrees with the philosophical orientation of the parent organization is another matter. Specifically, the new coding proposal suggests thinking that is reductionistic in its orientation and asks practitioners to parse function into subsystem levels of function. So, the more subsystems that you consider in your evaluation, the more 'complex' that evaluation is determined to be, and the more you will be able to be reimbursed for such activity.
So on an esoteric level, there is philosophical incoherence when considering the contradistinction between a reductionistic coding proposal and the stated philosophical orientation of the profession, which notably does not talk about counting up numbers of systems-level performance deficits.
Perhaps worse, the incoherence is carried into the realm of treating different areas of specialization differently. On a practical level this coding proposal will have the obvious impact of causing operators in Medicare settings (through direct action or through employer mandate) to search for ways to include the minimal number of performance deficits in their evaluations so that reimbursement can be maximized. Anyone who has spent any amount of time in a Medicare environment will attest to this kind of thinking. This action will not serve the needs of those who are recipients of services, but will definitely serve the interests of the profit-driven long term care industry.
CMS is not dumb, and they see the upcoding coming like a freight train. They rebut the proposal by suggesting budget and payment neutrality, which basically nullifies the whole point of a tiered coding system. But not really - because as soon as employers catch wind of CMS paying the same for a 30 minute evaluation or a 60 minute evaluation take one guess on what employers will demand from employees - that's right - nothing more than a 30 minute evaluation for any patient because the reimbursement will be the same!
The upcoding planners who came up with this multi tiered system will have to wait for a year when no one is paying attention and they can sneak in payment differentials, perhaps when the budget is not so lean. The whole scheme stinks to high heaven. In any case the patients are not being served well.
Medicare is a system that tends to set a standard for the rest of the insurance industry. So, what is adopted in Medicare will eventually filter down to state Medicaid programs, and other insurance programs serving other patient populations. How will promotion of a subsystem level orientation to billing that maximizes profits for savvy operators impact other systems? Will we come around to a for-profit mentality in school systems? Will school based therapists begin counting up areas of performance deficits to maximize their billing? If not - what is the difference and why are these two systems so different?
Here the specialization problem is evident, and the assignment of different local actors to specialized areas of policy causes grand incoherence. For example, in school systems professional associations are promoting the concept of 'workload' instead of 'caseload.' By doing this they are promoting a kind of thinking that is in direct opposition to the coding systems that they are creating in the Medicare system that will eventually come down and settle into Medicaid reimbursement. Operating on a 'workload' type of thinking means that time needs to be created in the day for non-reimbursable activities like talking to teachers, attending meetings, providing non-billable consultation, and many other activities.
Why not promote a system that facilitates 'workload' type of thinking in long term care environments that are being reimbursed by Medicare? Here is a question for those in leadership who are responsible for the disconnected policy decision to promote profiteering in one sector and not in another: WHY?
Does it have something to do with the fact that long term care environments are for-profit oriented? Is that why we are creating a system where we try to click as many boxes in our electronic health record, knowing that the more boxes we click means that we will get more revenue?
And is it because school systems are municipal funded, meaning no one is trying to make a profit? Is that why professional associations are more free to suggest 'workload' level approaches to care that are undoubtedly more costly and less efficient and less profit oriented?
This all leads to some pretty important questions. Are we so specialized that our own leadership lacks the ability to see the obvious disparate methods we are using in different systems? Have the operators within systems found ways to pull the strings of the professional associations in such a way that methods are promoted that maximize billing opportunities? Or is this all rather planned, and is the leadership in charge absolutely aware of their philosophic incoherence, and they are just counting on the professional specialists working in one area to never speak with the professional specialists working in the other area?
In either case, my suggestion is for the therapists to pull their heads out of their specialist niches. Maybe then the therapists working the streets will not be manipulated into ridiculous levels of productivity in one system and ridiculous levels of cost control in the other.
To paraphrase that famous philosopher George Clinton, 'Free your mind and your other parts will follow.'