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Latest Efforts and Resources

Advocacy

Scope of practice expansion is a long-standing, continuous, and complex concern in the health care field. AAPM&R is aware of the various concerns specifically plaguing physiatrists, from non-physicians to non-physiatrists, intent on expanding their scope of practice beyond their level of education, training, and experience. 

AAPM&R is taking action.

Your Academy remains vigilant about ongoing efforts by non-physician and non-PM&R providers to expand their scope of practice beyond their level of training, which may threaten the health and safety of patients and impact the livelihood of physiatrists.

AAPM&R's Scope of Practice Workgroup

Recognizing the growing concern of non-physician (and non-PM&R) scope of practice expansion, your Academy is addressing this issue through multiple committees, including a new Scope of Practice Workgroup. This workgroup is comprised of representatives from the Quality, Practice, Policy, and Research (QPPR) Committee, the Health Policy and Legislation (HP&L) Committee, and the Reimbursement and Policy Review Committee (RPRC), and AAPM&R’s representative to the AMA Scope of Practice Partnership (SOPP).

Scope of Practice Partnership with the American Medical Association (AMA)

Your Academy, as a member of the AMA Scope of Practice Partnership (SOPP), actively engages in the collaborative effort of the AMA, American Osteopathic Association (AOA), national medical societies, state medical associations and state osteopathic medical associations to oppose scope of practice expansions by non-physician providers that threaten the health and safety of patients. The SOPP achieves this goal through legislative activities, regulatory activities, judicial advocacy, and programs of information, research and education. Active participation in this collaborative ensures physiatry is represented and contributes to SOPP’s goal to protect the health and safety of patients whose well-being may be threatened by health care practitioners who lack the education, training or experience to perform procedures for which they seek licensure or recognition.

Protecting Physiatry’s Leadership Within Rehabilitation Hospitals

In 2019, the Centers for Medicare and Medicaid Services (CMS) released the Proposed CY 2020 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Rule, including a proposal to amend the definition of a rehabilitation physician to clarify that the determination as to whether a physician qualifies as a rehabilitation physician (that is, a licensed physician with specialized training and experience in inpatient rehabilitation) is made by the IRF.” In response to this proposal, AAPM&R convened an ad hoc Rehabilitation Physician Workgroup and submitted a strongly worded letter to CMS urging CMS not to finalize its proposal to weaken the definition of rehabilitation physician and requesting that CMS delay any changes to current regulations until stakeholders can develop a consensus approach for protecting the quality and integrity of IRF care. In additional to several additional advocacy actions, AAPM&R secured support from 40 prestigious organizations representing patients, physicians, and large inpatient rehabilitation hospitals on a stakeholder letter to CMS.

In July 2020, CMS finalized the IRF PPS Rule for 2020. In the final rule, CMS deferred to the IRF to define and assess the definition of “rehabilitation physician.” Despite this outcome, we are immensely proud of the work more than 1,100 of our members put into advocating against this proposal. Our members demonstrated that physiatrists are advocates for their patients, in and out of the treatment setting. We know it will take time and perseverance to be successful, but we are stepping up and planning a long-term, strategic initiative. We are making physiatrists’ voices heard. We are advocating for physiatry’s value in medicine.

Click here to read the full timeline of our past efforts.

Click here to read about AAPM&R’s leadership in scoring an enormous advocacy win for the FY 2021 IRF PPS Proposed Rule.

Resources

From ongoing collaborations with the American Medical Association (AMA) to a full toolkit of position statements, we plan to continue developing tangible resources to assist physiatrists in addressing scope of practice issues.

Your Academy's Latest Efforts to Defend Physiatrists' Scope of Practice


View the full list of AAPM&R advocacy letters.


July 1 – New Medicare Prior Authorization Requirement for Facet Procedures

Jun 08, 2023

Effective July 1, the Centers for Medicare and Medicaid Services (CMS) has expanded its Prior Authorization for Certain Hospital Outpatient Department (OPD) Services program to include facet joint procedures.  Specifically, CPT codes 64490-64495 and 64633-64636, will require prior authorization when performed in a hospital outpatient department.  This includes both place of service 19, off-campus outpatient hospital) and place of service 22 (on-campus outpatient hospital).   Prior authorization is not required for facet procedures provided in other places of service. 

Providers who typically bill facet procedures performed in hospital outpatient departments should have received a letter describing this new requirement in the spring.  When the program begins next month, prior authorization requests can be submitted through the Electronic Submission of Medical Documentation (esMD) platform.  The addition of facet procedures to the OPD Prior Authorization program was finalized in the 2023 Outpatient Prospective Payment System final rule.  AAPM&R voiced concerns about this policy change in our comment letter last September.  Reducing physician burden associated with prior authorization policies is a key advocacy priority for the Academy.  If you have any questions, please contact healthpolicy@aapmr.org.