The Centers for Medicare & Medicaid Services should openly urge Congress to change the way therapy services are reimbursed, the nation’s largest long-term care provider association stated in recent written comments to CMS Administrator Marilyn Tavenner.

The American Health Care Association/National Center for Assisted Living pressed for three changes in particular: repealing “arbitrary” Part B therapy caps that limit access to needed services; reforming the “flawed” outpatient therapy medical review process, in order to create a system more likely to identify improper payments; and the collection of standardized outpatient therapy data, rather than the current non-standardized data that is “administratively complex” and not very useful.

CMS needs Congressional action in order to repeal the caps and reform medical review. The agency should issue a public statement to Congress advocating for the three proposed changes, AHCA stated. The Sept. 2 document served as the association’s official comments on proposed policies in the Medicare physician fee schedule for calendar year 2015.

AHCA also called for changes to the Recovery Audit Contractor program, including doing only post-payment reviews and implementing further limits on additional documentation requests. The provider association applauded CMS for pausing the Recovery Auditor program and undertaking improvements, but wants more information about what these enhancements are and when audits will fully resume.

The 11-page document also included comments on a number of other topics, including re-valuing potentially misvalued codes and potential provider burdens created by CMS evaluations of new payment and delivery models.