Statement by APTA President on 2011 Medicare Physician Fee Schedule Final Rule

November 2, 2010

Today the Centers for Medicare and Medicaid Services (CMS) released the 2011 Medicare Physician Fee Schedule Final Rule, which, I am disappointed to report, contains significant cuts to outpatient therapy services that will negatively impact physical therapists and millions of patients. Under a new multiple procedure payment reduction (MPPR) policy, physical therapists will see a 7%-9% reduction in payment for these services starting January 1, 2011.

The association is deeply concerned about this policy. APTA has worked diligently these past few months educating CMS, White House officials, the Medicare Payment Advisory Commission (MedPAC) and other policymakers about the detrimental effect the MPPR policy will have on physical therapists and the patients we serve. The initial MPPR proposal called for an 11%-13% cut in payments and, while our actions did have an impact, we are nonetheless seriously troubled by this final rule. This lesser reduction of 7%-9% will still mean disturbing repercussions for outpatient therapy providers and their patients. As such, APTA is now aggressively exploring all legal, regulatory, and legislative options to negate the MPPR policy.

APTA believes this policy is unjustified, as it is based on flawed analysis conducted by CMS in the agency's effort to avoid duplication of payment when multiple services are furnished during a session or day. As we know, the practice expense values for the codes reported by physical therapists had already been reduced to avoid duplication during the Relative Value Update Committee (RUC) review process, thus making the MPPR an unfair and unnecessary policy. In addition, CMS only examined the median number of units in private practice therapists' offices and physician offices, which account for approximately 35% of expenditures. Data from skilled nursing facilities, hospitals, rehabilitation agencies, and comprehensive outpatient rehabilitation facilities, which account for the remaining 65% of expenditures, were not taken into account. And, CMS excluded all dates of service during which one unit of service is billed, further skewing the data on which this policy is based.

Lastly, the final fee schedule rule includes several other provisions important to physical therapists, including the implementation of the $1,870 therapy cap without an exceptions process, the projected cut in the sustainable growth rate/conversion factor of approximately 30%, and the expiration of the geographical practice cost index (GPCI) floor. Also in the rule, CMS discusses options for therapy payment alternatives, quality reporting under the physician quality reporting initiative (PQRI), and application of a MPPR policy for therapy services under Medicare Part B.

APTA will work to ensure that CMS establishes payment policies that guarantee appropriate payment for the high quality services we provide our patients. The association is committed to being a leader in policy change and in developing payment models that accurately reflect the care and treatment provided by physical therapists.

APTA President R. Scott Ward, PT, PhD 

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