Adoption of Multiple Procedure Payment Reduction (MPPR) by Nonfederal Payers

Several private and workers' compensation payers are implementing the Centers for Medicare and Medicaid Services' (CMS) multiple procedure payment reduction (MPPR) policy that reduces the practice expense part of payment to physical therapists in all settings.

MPPR is designed to avoid duplicate payment for practice expenses when multiple procedures are delivered to the same patient on the same date of service. CMS started applying this policy to "always therapy" services on January 1, 2011, despite the objection of therapy stakeholders. From January 1, 2011, to March 31, 2013, MPPR as applied by CMS included a 20% reduction on the practice expense for nonfacility providers and a 25% reduction for facility providers. The MPPR increased to 50% for CMS providers in all settings on April 1, 2013.

APTA continues to assert that the application of MPPR to physical medicine services is a flawed policy because the practice expense values for these CPT codes were already reduced to avoid duplication during the American Medical Association (AMA) Relative Value Scale Update Committee (RUC) process. In fact, the time spent on the pre-service and post-service activities was spread across 3 units of services based on the assessment that the typical therapy visit is approximately 45 minutes. The fact that certain efficiencies exist when multiple therapy services are provided in a single session was explicitly taken into account when relative values were established for these codes. Therefore, an additional cut to the practice expense of therapy service codes is arbitrary and likely to restrict patient access to vital physical therapy services. (See APTA's letter to Aetna dated October 3, 2011(.pdf).)

With several nonfederal insurers now following the CMS policy, you need to take a careful look at your contracts with payers to determine the risk of MPPR adoption, particularly for Medicare Advantage plans but also for commercial plans.

APTA Comments to Nonfederal Payers

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