Some practices in Iowa have not been successful in utilizing the Compact Privilege to bill Medicare. We are encouraging you to read this if you are considering hiring an employee who has a Compact Privilege and not an Iowa license. Please see below for the history and what APTA/IPTA are doing to address this. 

As of this week, 18 states are issuing compact privileges. Approximately 1,000 therapists have received compact privileges. Late last year, APTA and the PT Compact Board staff were alerted that Iowa was not allowing Medicare claims for services delivered under a compact privilege. Compact staff shared with APTA that one therapist in Oregon may have had a similar issue, but this matter was raised in 2018 at one time by one person and never raised again. To our knowledge, 16 of the 18 compact states have not received communications from therapists regarding difficulty with Medicare claims. WPS is the Medicare contractor for Iowa, Missouri, Nebraska and Kansas. (Only Kansas is a non-compact state.) Missouri began issuing compact privileges in July 2018 and it is reasonable to assume that at least one Medicare beneficiary was served by a therapist with a compact privilege. Missouri has not identified any problems with Medicare claims. Nebraska began issuing privileges in April 2019. Like Missouri, Nebraska has not identified any problems with Medicare claims.

APTA staff have been working closely with the PT Compact Licensure staff on this topic to coordinate messaging and strategy. On December 18, 2019, APTA wrote the Center for Medicare and Medicaid services (letter attached) that details our read of the regulations on this topic. The gist of this letter: Compact privileges are the legal equivalent of a traditional license issued by a state licensing board. The PT Compact allows eligible physical therapists and physical therapist assistants to practice in member states. Physical therapists and physical therapist assistants holding a compact privilege should have the same rights and responsibilities as those otherwise licensed, including the ability to enroll as a Medicare provider and receive reimbursement. In response to this letter, CMS has agreed to meet with APTA. We are working to set a date and anticipate this meeting will occur in January 2020.

In the APTA meeting with CMS, we will advocate that guidance should be published clarifying that compact privileges are equal to a traditional license. Ideally, this guidance could be released in the first quarter of 2020. If that action isn’t taken, our next opportunity will be to influence the 2021 Medicare physician fee schedule rule that will be published in draft form in July and final form in November.