Quality Payment Program 

August 2018

On July 12, 2018, CMS released a notice of proposed rulemaking (NPRM) detailing proposed changes to the Quality Payment Program (QPP), including the expansion of eligible clinician types to include occupational therapist. 

General information on the Quality Payment System: The QPP was established by Congress in the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015.  The QPP contains two tracks clinicians can choose to participate: the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs).  Initially, the clinician types that were eligible for the first two years of participation (2017 and 2018) included physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists.  For the 2019 performance year, CMS is proposing to add Occupational Therapists and other disciplines for the definition of "eligible clinician."  Public comments on the proposed rules are due no later than September 10, 2018.

Clinicians or groups who are eligible to participate in MIPS are scored based on their performance in four categories: quality, cost, improvement activities, and promoting interoperability.  

To view the CY 2019 Physician Fee Schedule proposed rule

For a fact sheet on the CY 2019 Quality Payment Program proposed rule





NCBOT OTA Supervision Changes

July 2018

As of July 1st 2018, NCBOT has officially changed the supervision requirements for OTAs. Historically close supervision has been required for OTA's during their first year of practice. The Board now requires general supervision for all levels of OTA practice, including entry level. However, practitioners remain responsible for maintaining standards of practice as outlined in our Code of Ethics including ensuring safe and effective service delivery of occupational therapy services and fostering professional competence and development. 
The new rules can be found here


House Bill 967-Telemedicine Policy

Legislative Update 



Update on Telemedicine Policy Bill:
House 967 Telemedicine Policy:  This bill started out as a bill to expand opportunities in the area of telehealth for providers listed in Chapter 90 of the North Carolina General Statutes, like occupational therapists.  The bill, however, was changed to a study bill before being adopted by the House of Representatives.  The Senate did not vote on HB 967 before adjourning.  NCOTA plans to closely monitor the progress of telehealth initiatives and advocate for expanded telehealth opportunities for occupational therapists.   
Update on Medicaid Transformation:
House Bill 156 Medicaid PHP Licensure and Transformation Modifications:  This bill, adopted by the General Assembly, puts in statute elements of the Medicaid transformation plan championed by the North Carolina Department of Health and Human Services.  The proposed transformation plan will bring physical health services into a capitated managed care approach similar to the current MCO model. House Bill 156 requires the Department of Health and Human Services to submit a report by October 1, 2018, to the Joint Legislative Oversight Committee on Medicaid and NC Health Choice containing proposed additional needed legislative changes and sets forth a time frame within which the Department of Health and Human Services must issue requests for proposals.


House Bill 403 Medicaid and Behavioral Health Modifications:  This bill, adopted by the General Assembly, sets in motion the development of the tailored plans, an integral part of the Medicaid Transformation plan developed by the Department of Health and Human Services. Details on the implementation of tailored plans can be found in the implementation plan link below.  


Department of Health and Human Services Implementation Plan for Tailored Plans


Pursuant to House Bill 403, the North Carolina Department of Health and Human Services issued this Implementation Plan for Behavioral Health and Individuals with Developmental Disabilities Tailored Plans to the NC Joint Legislative Oversight Committee on Medicaid and NC Health Choice on June 22. 




Advocacy Update


This is a website that is helpful with finding out proposed plans, policies, manuals and public comments regarding Medicaid Managed Care. This link includes DHHS Medicaid Managed Care policy papers focused on specific subjects in relation to the proposed Medicaid and NC Health Choice care program designs. Topics include:

Supporting provider transitions

Prepaid Health Plans

Behavioral Health and IDD Plans

Clinical Coverage policies

And others

[email protected] is an email that is helpful for any questions




AOTA's Message Regarding OTA Payment Changes in Budget Bill

Click here to read the official statement


Our advocacy is working!


On February 9, 2018, the president signed into law a bill that repeals the cap on Medicare part B outpatient therapy services; this has been 20 years in waiting! This therapy cap created significant barriers for our client’s with chronic, long-term conditions and clients that required ongoing services.  This cap previously caused many of our clients financial hardships for paying out of pocket after meeting their cap or if they could not afford services possibly permanent and debilitating injuries. We can now treat based on Medical Necessity!


 AOTA President, Amy Lamb issues a public statement: