RESPONSE DUE JUNE 16, 2003

TRICARE Proposed Rule
Federal Register Volume 68, No. 73

TRICARE, under the Department of Defense, has requested written comments regarding proposed rule to make several changes to the TRICARE program that was enacted by Congress in the National Defense Authorization Act for Fiscal Year 2002 (NDAA-02). Specifically under this proposed rule, TRICARE provides a limiting interpretation of rehabilitative therapy as physical therapy, speech therapy, and occupational therapy.

ATRA ACTION:

1. Visit the proposed rule at
http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2003/pdf/03-9153.pdf

2. Prepare your own response using the draft prepared by ATRA. Please include specific information about your practice as a recreational therapist in the first paragraph.

3. Mail a hard copy of your letter to Medical Benefits and Reimbursement Systems at the address provided on the draft letter. PLEASE PROVIDE A CC: TO THE ATRA NATIONAL OFFICE, 1414 PRINCE STREET, SUITE 204, ALEXANDRIA, VA 22314. It is very important for us to track our responses to TRICARE!

4. Go the ATRA Website>Public Policy Section for ATRA’s official TRICARE response (to be posted June 12, 2003)

5. Watch the ATRA website for future announcements and postings.
Email or call the ATRA National Office if you have any questions. THANKS!

American Therapeutic Recreation Association
founded in 1984

TRICARE ATRA Action Alert
Response due June 16, 2003

TRICARE Proposed Rule Definition

“Rehabilitation therapy as defined in Statutory 199.2 of this part to improve, restore or maintain function, or to minimize or prevent deterioration of function, of a patient when prescribed by a physician. The rehabilitation therapy must be medically necessary and appropriate, must be necessary to the establishment of a safe and effective maintenance program in connection with a specific medical condition, and must not be custodial care.”

The TRICARE interpretation of Rehabilitation Therapy includes “physical therapy, speech therapy, and occupational therapy”. This limiting interpretation does not represent current practice in rehabilitation care.

ATRA Position:

Recreational therapy should be an identified discipline in the interpretations of TRICARE rehabilitative therapy.

Talking Points
(see instructions for Action Alert Response)

· Recreational Therapy is recognized as a rehabilitation therapy by external accrediting agencies such as the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), CARF . . . the Rehabilitation Commission as well as by federal government agencies such as the Centers for Medicare and Medicaid Services (CMS), the U.S. Department of Veterans Affairs, and the U.S. Department of Labor.

· Recreational therapy is considered a cost effective rehabilitative therapy that should be available to rehabilitation patients when medically indicated

· Recreational therapy, like other therapies meet the federal government’s definition of active treatment that is “services are furnished under an individualized plan of treatment, reflect a reasonable expectation to improve the patient's condition and are supervised and evaluated by a physician.” Recreational therapy is specifically recognized as a primary rehabilitation therapy in many state health service plans.

ATRA Draft Response Letter on TRICARE

(ATRA Action Alert - Use blank stationary or agency letterhead if you have permission)

date

Ann N. Fazzini
Medical Benefits and Reimbursement Systems
TRICARE Management Activity
16401 East Centretech Parkway
Aurora, CO 80011-9066

Dear Ms. Fazzini,

I am a recreational therapist working in XYZ type of facility and appreciate the opportunity to provide comments to the Department of Defense regarding the TRICARE program.

As a recreational therapist I provide treatment services that are physician prescribed and improve, restore, or maintain function, or minimize or prevent deterioration of function. As posted in the Federal Register, Volume 68, No. 73 Proposed Rule, the TRICARE interpretation of rehabilitation therapies is very limiting. Recreational therapy should be added to the list of available services defined as rehabilitation therapy.

Recreational Therapy plays a critical role in the comprehensive health and rehabilitation of individuals with disabilities and illnesses by contributing to the broad spectrum of health care through the delivery of treatment services. Recreational therapy, like other therapies meet the federal government’s definition of active treatment that is “services are furnished under an individualized plan of treatment, reflect a reasonable expectation to improve the patient's condition and are supervised and evaluated by a physician.” Current research supports the inclusion of recreational therapy as a rehabilitation intervention that is instrumental in improving and maintaining physical and psychosocial functioning, preventing secondary health conditions, enhancing independent living skills and overall quality of life.

Recreational Therapy is recognized as a rehabilitation therapy by external accrediting agencies such as the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), CARF . . . the Rehabilitation Commission as well as by federal government agencies such as the Centers for Medicare and Medicaid Services (CMS), the U.S. Department of Veterans Affairs, and the U.S. Department of Labor. It would seem inconsistent for TRICARE to provide a limited mix of available therapy services contrary to other governmental agencies.

Thank you for the opportunity to review and provide comments to the proposed rules regarding the revisions of the TRICARE program. I look forward to more opportunity to provide feedback during this process.

Sincerely,

Your Name and address here

cc: ATRA National Office