Transcript Advocacy or what does TOTA do for you and for the profession

What’s new
Mary Hennigan, OTR, MBA
November 7, 2014
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Mental Health
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“One pager”
Carrying legislation, 2015
Testimony
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David Lakey, MD Commissioner of Department of Services regarding the mental health workforce
shortage and OT’s role in mental health, August 27, 2014
Bridgett Piernik-Yoder, PhD, OTR testified at the House Select Committee of Health Education and
Training, August 28, 2014 regarding education and training of occupational therapists
Robin Clearman, OTR testified at the House Select Committee of Health Education and Training,
September 16, 2014 regarding occupational therapy’s role in mental health.
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Mental Health testimony
• Robin Clearman, OTR testified at the House Select Committee of
Health Education and Training, September 16, 2014 regarding
occupational therapy’s role in mental health.
• Shirley Wells, Dr.P.H., OTR testified at the County Affairs
Committee, October 27, 2014 regarding occupational therapy’s
role in mental health.
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Scope of Practice
• Modern Healthcare meeting in Dallas May, 2014.
• Panelists included Joel Allison, CEO, Baylor Scott & White Health, Dr. Nancy
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Dickey, Professor, Texas A&M University, President Emeritus, Texas A&M
University Health Science Center and Edward Salsberg, Professor, George
Washington University School of Public Health and Health Services.
During their presentations they referred to the necessary scope of practice
changes that will be required to implement the Affordable Care Act.
Additionally they referred to Texas 1115 Health Care Transformation Waiver
and super aides (high school graduates with on the job training) as primary
care providers in the
home.
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Meetings
• Texas Medicaid Therapy Stakeholder Meeting March 3, 2014
• Prior Authorization Listening Session June 26, 2014
• Texas Health and Human Services Commission public hearing regarding
Medicaid rates August 21, 2014
• Texas Board of Occupational Therapy Examiners Meeting September 5,
2014
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Splints
• Communication from therapists working with Palmetto GBA, a fiscal
intermediary of the Centers for Medicare and Medicaid (CMS).
• Palmetto GBA is denying charges from OTs fabricating "custom orthosis"
(splints) because the OT does not have an orthotist license.
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This is an erroneous interpretation of the Orthotists and Prosthetists Act.
The regulation of Orthotists and Prosthetists specifically excludes OTs.
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Splints
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"This chapter does not restrict a person who holds a license issued by another state agency from
performing health care services within the scope of the license holder's applicable licensing act if the
license holder: (1) practices in conformance with the applicable laws and rules relating to the person's
license; and (2) does not: (A) violate Section 605.251; (B) represent to others that the license holder
practices orthotics or prosthetics; or (C) use the terms "prosthetist," "prosthesis," "prosthetic,"
"artificial limb," "orthotist," "orthosis," "orthotic," or "brace" or the letters "LP," "LPA," "LO," "LOA,"
"LPO," or "LPOA" or any derivative of those terms or letters in connection with the license holder's
name or practice. (V.A.C.S. Art. 8920, Sec. 21(a).)
• TOTA has been actively protecting your ability to make splints for several
years. We posted information on the web site for therapists to use when
dealing with splint denials.
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Productivity and supervision (combatting fraud
and abuse)
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Responded to numerous e-mails from staff of the Data Analytics and Fraud
Detection Division, Office of Inspector General, Health and Human Services
Commission regarding OTA supervision, numbers of hours therapists work,
etc. Sent supporting TBOTE and AOTA documentation.
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Code 97535
• Numerous e-mails with staff of HHSC regarding Code 97535. The code has
been approved for OT utilization. CPT code 97535 is self-care/homemanagement training (such as ADL and compensatory training, meal
preparation, safety procedures, and instructions in the use of assistive
technology devices/adaptive equipment) with direct, one-on-one contact by
the provider, each 15 minutes.
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TMHP-Texas Medicaid and Healthcare
Partners
• TMHP is a group of contractors under the leadership of Accenture.
Accenture administers Texas Medicaid and other state health-care programs
on behalf of the Texas Health and Human Services Commission
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TMHP Rule Making
• Home services not permitted at day care centers.
• CCP Comprehensive Care Program, Acute and Home Health
• High frequency-3> a week-rapidly changing, potential for rapid progress or
rapid decline, plan of care requires frequent modification, client requires
high frequency of intervention for limited duration (60 days or less)
• Moderate frequency-2 times per week, client is making functional progress,
critical period to restore function or at risk of regression, plan needs to
adjusted weekly or more often than weekly, complex needs require ongoing education
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TMHP Rule Making
• Low frequency-one time per week or every other week, progress has
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slowed, plan needs to be adjusted weekly, condition is stable plan changes
slowly
Maintenance-every other week to monthly, progress as slowed or stopped,
ongoing therapy required to maintain, limited progress
Discharge-goals achieved, therapy no longer produces functional,
measurable outcome, patient declines, unable to progress, no benefit
4 units per day per therapy unless appealed
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Questions?
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