APTA Urges Against Payment Policies Outlined in GAO Report

ALEXANDRIA, VA, September 4, 2009 —The American Physical Therapy Association (APTA) is urging against the adoption of payment policies outlined in a Government Accountability Office (GAO) report1 released Monday that recommends the Centers for Medicare and Medicaid Services (CMS) reduce Medicare payments for physical therapists and other health care providers who perform multiple procedures on the same patient on the same day. Under this proposal, providers would likely be reimbursed for these services at a rate that is below the cost of providing the services to their patients. Such payment rates would severely hinder the ability for some providers to keep their practices open. If practices do close, there is a strong likelihood that patients will have limited access to physical therapy services and other necessary procedures, says APTA.

According to GAO, provider fees may not always reflect "efficiencies" when certain services are performed together, such as reading a patient's chart once before performing multiple procedures. In an effort to avoid duplication of payment, GAO recommends that CMS systematically review commonly performed procedures and implement a multiple procedure payment reduction (MPPR) to capture efficiencies in both provider work and practice expenses, where appropriate. GAO based its conclusion on a review of a sample of the most costly service pairs, which, GAO says, included certain physical therapy services. However, the report does not specify the service pairs that were used in making this recommendation. GAO says that the report "focuses on illustrating the value of CMS's taking a more systematic approach, rather than focusing on specific service pairs…"

"We believe that the GAO report is fundamentally flawed in its construct and conclusions," said APTA President R. Scott Ward, PT, PhD. "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."

In addition to implementing MPPR policies, GAO recommends focusing on service pairs that have the most impact on Medicare spending and monitoring provision of services affected by any new policies it implements to ensure that providers do not change their behavior in response to these policies.

Physical therapists are highly-educated, licensed health care professionals who can help patients reduce pain and improve or restore mobility - in many cases without expensive surgery or the side effects of prescription medications. APTA represents more than 72,000 physical therapists, physical therapist assistants, and students of physical therapy nationwide. Its purpose is to improve the health and quality of life of individuals through the advancement of physical therapist practice, education, and research. In most states, patients can make an appointment directly with a physical therapist, without a physician referral. Learn more about conditions physical therapists can treat and find a physical therapist in your area at www.moveforwardpt.com.


1. Medicare physician payments. Fees could better reflect efficiencies achieved when services are provided together. http://www.gao.gov/new.items/d09647.pdf. Published July 2009. Accessed September 2, 2009.

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