RE: Changes to Auto No-Fault Insurance Coverage
Last year, the Michigan Legislature made significant changes to our state auto insurance policies. Beginning July 1, 2020, auto policyholders may change their level of coverage from unlimited personal injury protection (PIP) to lesser levels of coverage. You may be receiving letters and emails from your insurance company about these changes. Please review thoroughly while making your personal decisions.
At this time, the fee schedules slated for those injured in auto accidents will not take effect until next year on July 2, 2021. As practitioners, we may not see the immediate impact of auto insurance reform on our clinical practice for many months. MiOTA encourages you to share the changes your clients experience with us and with your state legislators so we can advocate for client care during this transition.
RE: BCBS Michigan Denials for Outpatient Occupational Therapy Codes
On 6/3/2020, it was brought to our attention that several Occupational Therapists practicing in Outpatient settings began receiving denials for claims submitted after May 1, 2020 for codes commonly used by OT, including but not limited to the following:
97110 (therapeutic exercises)
97112 (neuro muscular re-education)
97014 (electrical stimulation)
We immediately reached out to our Liaison with BCBS of Michigan and received the following information: Per the March 2020 version of The Record, several different changes to claims processing were being updated for various provider types. See original document at: https://www.bcbsm.com/content/dam/microsites/corpcomm/provider/the_record/2020/mar/Record_0320j.shtml
Per this publication, as of May 1, 2020, Occupational Therapy services will be required to be billed using the GO modifier.
If the claims were billed without the modifier, they will need to be rebilled with the modifier. BCBS has assured us that they will pay in the same way that they paid before 5/1/2020 once the GO modifier is added to the claim.
If that does not resolve the issue, please notify the MiOTA office immediately. Thank you!
Kirsten Matthews, MA, OTRL, CLT
BCBS Liaison, Michigan Occupational Therapy Association
Jeannie Kunz, MOT, OTRL, BCP
Advocacy Director, Michigan Occupational Therapy Association
Cathleen Johnson, OTD, OTRL, FMiOTA
Leader of the Executive Committee, Michigan Occupational Therapy Association
AOTA Telemedicine Information and Link
AOTA advocacy efforts succeeded! On April 30th, the Centers for Medicare & Medicaid Services (CMS) announced that occupational therapists, physical therapists, and speech language pathologists can now perform telehealth services for Medicare beneficiaries.
Read about it here: https://www.aota.org/Advocacy-Policy/Federal-Reg-Affairs/News/2020/Medicare-Telehealth-Success.aspx?fbclid=IwAR24mHEIO9Fg02nxDap-DrWKpoTThvmm4HGqU33WxfnIEdMWyFVgKVrrt1s
COVID-19 Information and Links
MiOTA is working with state and national authorities to bring us the most accurate and up-to-date information on COVID-19 specific to our state. Please be aware that information is subject to change quickly during this challenging time.
For general information on national issues,
If you are an occupational therapy practitioner with questions, please visit: https://www.aota.org/Practice/Health-Wellness/COVID19/practitioners-faq.aspx
If you are an occupational therapy student, please visit: https://www.aota.org/Practice/Health-Wellness/COVID19/educators-students-faq.aspx
For client recommendations and suggestions, please visit: https://www.aota.org/Practice/Health-Wellness/COVID19/clients-faq.aspx
Not only is hand washing the best way to prevent the spread of germs, but it is also one of the most important activities of daily living during this outbreak!
Dear MiOTA Members,
I have been asked by many individuals regarding how this emergency is impacting one’s capacity to achieve PDU time to meet renewal requirements for May 31st. MiOTA has reached out to the LARA Michigan Occupational Therapy Board and obtained the information below. See message below.
Thank you for your membership and support of MiOTA,
Cathleen Johnson, Membership Director and Incoming Leader of the Executive Committee.
Dear Ms. Johnson,
In an effort to ensure that patients can be treated appropriately, the Governor issued Executive Order 2020-61, which temporarily suspends any law or regulation that requires continuing education for a health care professional to gain licensure or renewal of their licensure while the emergency declaration is in effect.
Through May 12, 2020, LARA may recognize hours worked responding to the COVID-19 emergency as hours toward continuing education courses or programs required for licensure. So, if a regulated professional demonstrates proof of working in response to COVID-19, whether it is handling patient care or providing support in another way that is directly related to the pandemic, those hours may count toward continuing education requirements as long as they were earned before May 12, 2020 at 11:59 p.m.
If audited, licensees will be required to provide reasonably sufficient evidence to show that the hours they worked from the effective date of EO 2020-13 through May 12, 2020, were hours worked responding to the COVID-19 emergency. Examples of reasonably sufficient evidence include, but are not limited to, a written attestation by the licensee, a Human Resources Administrator, or a direct supervisor at work to the timeframe, amount, and nature of the hours worked.
If a licensee wishes to claim his/her hours worked responding to the COVID-19 emergency as CE but does not report to a hospital, please note that a self-attestation regarding those hours is sufficient. One hour worked responding to the COVID-19 emergency will amount to one hour of CE.
After May 12, 2020, licensees experiencing difficulty with completing continuing education courses that have been canceled due to emergent issues with Coronavirus Disease 2019 (COVID-19) should make every effort to schedule alternative courses in order to meet any necessary continuing education requirements. Many organizations offer continuing education online that qualify as in person and live. An online course may qualify as live, during this state of emergency period, if it allows you to interact in real time with the course presenter (it cannot be a recorded presentation).
Please note that R 338.1252(2) of the Occupational Therapist Administrative Rules requires “1/2 of the required continuing education contact hours shall be completed in person using live, synchronous contact. The remaining continuing education contact hours may be completed in any other format.” In addition, R 338.1252(1)(a) limits not more than “10 credit hours to be earned during one 24-hour period for on-line or electronic media, such as videos, internet web-based seminars, video conferences, online continuing education programs, and on-line journal articles.”
MCL 333.16205 of the Michigan Public Health Code affords licensees the ability to request a waiver of continuing education by the Board. Requests must be received before the expiration date of the license. However, approval of waivers are not guaranteed and the final determination rests with the board. If requesting a waiver, you may wish to provide documentation to support your written request.
Andria M. Ditschman, JD
Senior Policy Analyst
Boards and Committees Section
Bureau of Professional Licensing
Michigan Department of Licensing and Regulatory Affairs
Important Update Regarding NBCOT Renewal Extension:
If you were due to renew your NBCOT certification or registration at the end of March please be aware that considering COVID-19 and its’ impact on the nation, NBCOT has extended the renewal time frame 2020.
NBCOT will extend the renewal deadline for 2020 until May 31.
- All certificants due to renew in 2020 will retain their active OTR® or COTA® certification until May 31, 2020.
- This gives you two additional months to obtain the units required for certification renewal.
- If you do not renew by May 31, 2020, your certification status will change to Expired on June 1.
- If you renew your certification after May 31, 2020, you will be charged the late fee.
Lansing Lobby Day:
On February 13, 2020, MiOTA held our annual Lansing Lobby Day on Michigan’s Capitol Hill. While the weather wasn’t kind that morning (a snowstorm hit during the morning rush hour), we had a strong showing of over 90 members who braved the cold and snowy morning to support their profession.
Held at the Radisson Hotel in Lansing, Lobby Day participants met with their local House Representative, Senators, and legislative staff members throughout the day. They lobbied on behalf of MiOTA on the following topics:
- Autism and Occupational Therapy
- House Bill 4108: Mandatory Reporters
- Auto No-Fault Insurance
MiOTA holds Lansing Lobby Day yearly to maintain and increase our visibility with our legislators throughout the state and share our concerns. This year, our main lobbying topic (Autism) was a member-generated concern shared through our fall survey. It was timely and important due to recent budget cuts and reinstatements of Autism program funding at the state-level. While these cuts did directly impact occupational therapists, they offered an opportunity for MiOTA to share occupational therapy’s long and ongoing contribution to ASD treatment throughout the state of Michigan.
The Advocacy Committee would like to share a huge thanks to our participants for coming out on that blustery February morning! In addition, a huge thanks to Dr. Steven Eberth, Alyssa Baker, Joanna Coddington, Bret Marr, Lisa Johnson, and Kirsten Matthews for their support in developing this event.
Be on the lookout for further communications from MiOTA’s Advocacy Committee on other state and nation-wide issues affecting therapists locally and throughout the country.
Jeannie Kunz, MOT, OTR/L, BCP
AOTA Board Certified in Pediatrics
MiOTA Advocacy Director
Payer Driven Payment Model Updates:
AOTA has been monitoring changes with practitioners who have been impacted by the shift to Payer Driven Payment Model (PDPM). They want to hear experiences from AOTA members and non-members alike. If your practice has been affected by changes related to PDPM, please follow this link to report your concerns: https://www.aota.org/Publications-News/AOTANews/2019/PDPM-Changes-SNF-CMS.aspx
If you are concerned with fraud, abuse, or non-compliance, you can reference the following website for support and information: https://www.aota.org/Practice/Ethics/Tools-for-Productivity-Requirements/compliance-reporting-fraud-abuse-medicare.aspx
For additional support, AOTA members can use the CommunOT blog to reach out to other practitioners for support and resources.
Patient Driven Payment Model
Medicare, other payers, and health systems are moving to emphasize the value of services provided rather than rewarding the volume of services. This transition provides opportunities for occupational therapy practitioners to highlight their distinct value by understanding and applying quality measures to everyday practice. Practitioners will be financially rewarded for demonstrating value and potentially penalized for not meeting the value criteria. See below for education and resources supporting OT in the move from volume to value. (AOTA, 2019)
For an introduction to this model, please watch the following video provided by AOTA: https://www.youtube.com/watch?v=CIXDzqOed0c&feature=youtu.be
For more resources, use the following links from AOTA:
Continuing Education Requirements
There have been changes to the Public Health Code and Administrative Rules that require licensees and individuals seeking licensure to complete human trafficking training. When does this take effect? Administrative Rule R 338.1215 requires an individual licensed or seeking licensure to complete training to identify victims of human trafficking. This is a one-time training that is separate from continuing education (CE). Licensees who renew in 2018 must complete training by renewal in 2020; renewals completed in 2019 must complete training by renewal in 2021, and renewals for 2020 by 2022. Beginning October 19, 2022, completion of training is a requirement for initial licensure. (Lara, 2017)
The one-time human trafficking training may be done through: a teleconference or a webinar, online presentation, live presentation, or printed or electronic media. Refer to the Administrative Rules for more information. The training must cover all of the following: understanding the types and venues of human trafficking in the United States; identifying victims of human trafficking in health care settings; identifying the warnings signs of human trafficking in health care settings for adults and minors; and identifying resources for reporting the suspected victims of human trafficking. The training may be acquired through any of the following: 1) A nationally recognized or state recognized, health related organization. 2) By or in conjunction with a state or federal agency. 3) An educational program that has been approved by the board for initial licensure, or by a college or university. 4) Reading an article related to the identification of victims of human trafficking as indicated above, and is published in a peer review journal, health care journal, or professional or scientific journal. If audited, licensees shall provide acceptable proof of completion. (Lara, 2017)"