Statement by APTA President on GAO Report on Payment for Efficiencies

September 3, 2009

In the coming weeks, APTA will communicate with officials from the Government Accountability Office (GAO) and the Centers for Medicare and Medicaid Services (CMS) to express our strong disagreement with the assumptions made in a GAO report issued this week that calls for reductions in Medicare payments for physical therapists and other health care providers who perform multiple procedures on the same patient on the same day.

According to report, GAO recommends that CMS systematically review services commonly furnished together and implement a multiple procedure payment reduction (MPPR) to capture efficiencies in both provider work and practice expenses, where appropriate, for these services; focus on service pairs that have the most impact on Medicare spending; and monitor provision of services affected by any new policies it implements to ensure that providers do not change their behavior (schedule services on different days) in response to these policies.

In reviewing the 350 most costly service pairs, the contractor medical directors identified 149 pairs where a MPPR would be appropriate. The 149 service pairs included physical therapy services; interventional radiology procedures; and tests such as additional imaging, pulmonary function, vision, hearing, and pathology.

APTA believes that this GAO report is fundamentally flawed in its construct and conclusions. It is inappropriate for GAO to release this report without identifying in the report the 149 code pairs on which it based its assumptions. GAO's analysis of the valuing of the CPT codes for physical therapists is incorrect as it failed to recognize that the time spent on pre- and post-service activities is spread across the number of services in a "typical" physical therapy session to avoid duplication of practice expenses. In addition, the report shows that GAO is unaware that a significant number of the CPT codes reported by physical therapists are direct 15-minute timed codes, and therefore, clearly, there is no duplication of service time.

APTA President R. Scott Ward, PT, PhD 

CSM 2016