Hospitals will become subject to the outpatient therapy cap beginning October 1, 2012. Although Section 3005 of the Middle Class Tax Relief and Job Creation Act of 2012 (MCTRJCA) extended the outpatient therapy cap exceptions process through 2012, two key changes to the 2012 process were required as a result of this legislation. One of those changes requires, for the first time, that the therapy cap be applied to outpatient hospital services. Additionally, the MCTRJCA imposed certain required data collection scheduled to begin in 2013.

Changes Effective October 1, 2012 -

CMS recently published a Therapy Cap Fact Sheet and question and answer document to provide information regarding the manual medical review process noted below and plans to issue a transmittal to include the new procedures in the applicable CMS manual. Following passage of the law, CMS released Transmittal 2457 [PDF] on April 27, 2012, with an effective date of October 1, 2012, to revise the CMS manual guidance to implement the other statutory requirements noted below. As a result of the MCTRJCA, the following key therapy cap changes go into effect for services provided on or after October 1, 2012, through the end of the year...

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