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