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Federal Regulatory Alert

from the American Physical Therapy Association


Brief Background

The Centers for Medicare and Medicaid Services (CMS) issued a proposed rule June 25, 2010, that updates 2011 payment rates for physician services, outpatient physical therapy services, and other services. In the rule CMS proposes to implement a multiple procedure payment reduction (MPPR) policy that would result in significant reductions in payment for outpatient therapy services. Specifically, CMS proposes to make full payment for the therapy service or unit with the highest practice expense value and payment of 50% of the practice expense component for the second and subsequent procedures or units of the service furnished during the same day for the same patient. The work and malpractice components of the therapy service payment would not be reduced.

The proposed MPPR policy would apply to both the services paid under the physician fee schedule (PFS) that are furnished in the office setting (physical therapists in private practice and physicians), and those services paid at the PFS rates that are furnished by outpatient hospitals, home health agencies (Part B), skilled nursing facilities (Part B), comprehensive rehabilitation facilities, rehabilitation agencies, and other entities that are paid by Medicare for outpatient therapy services. CMS estimates that it would result in a decrease in payment for outpatient therapy services of approximately 12-13% in 2011.  

CMS needs to hear from you to understand the implications the MPPR policy will have on your practice and your patients. In your letter you should highlight the following points:

1.      MPPR Policy for Therapy Services is Based on Poor Policy Assumptions by CMS:    CMS attempts to justify the MPPR policy because the agency believes there is duplication of services since physical therapists typically bill multiple CPT codes on the same date of service. This is incorrect. When the CPT codes therapists use were initially valued through the established and recognized the American Medical Association’s (AMA) Resource Based Relative Value System (RBRVS) process  used by all health care professions, reductions were made to the practice expense component to avoid duplication and represent the multiple procedural nature of physical therapy practice. In addition, CMS does not account for the multidisciplinary nature of therapy services or the patient’s clinical need for services in this policy

2.      MPPR Policy for Therapy Services will Result in Draconian Cuts that Will Limit Patient Access to Needed Services:   MPPR will result in a 12-13% cut to physical therapists under Medicare. This dramatic cut could have serious implications for both therapists and their patients. Practices may be forced to close, facilities may be forced to reduce their therapy workforce, and providers might seek strategies to reduce the number of Medicare beneficiaries they can see due to payment being under cost. The implications for limited access to care for Medicare beneficiaries if these practice close or do not see these patients is clear and would occur immediately if the MPPR policy is implemented. In your letter you may want to provide more specific examples of how this will impact your practice.

3.      MPPR Policy for Therapy Services could have Workforce Implications: Currently, there is a shortage of physical therapists, occupational therapists, and speech language pathologists. Payment policies that cut payments below the cost of providing the services will exacerbate the shortage immediately by staff reductions and practice closings due to inadequate reimbursement and in the future as individuals consider health care professions.

We urge you to write a letter to CMS immediately in response to this proposal. In order for CMS to consider your letter, it must be RECEIVED by August 24, 2010.

To learn more about the rule, read APTA’s summary at:

Address and Format for Comments

This is an excellent opportunity for physical therapists to tell CMS that it should not adopt a policy that inappropriately reduces payment for therapy services.

Comments can be submitted via mail or electronically. You can use the talking points provided or use the sample letter provided below. Please be sure to personalize the letter to ensure it accurately reflects the implication this policy will have on your practice/facility and your patients.

Use the following link to submit comments electronically.

Please fax your comments to APTA at 703-706-3246 or send a separate e-mail copy to

Enter your contact information in the required fields and then either copy and paste your comments in the text box or attach them as a Word or PDF document  in the same way you would attach a document to an e-mail. If you attach the document, please make sure to include a statement in the text box (e.g. “I am attaching comments in response to the proposed physician fee schedule rule.  Thank you for your consideration.”)

For comments submitted by regular mail, use the address included in the sample letter (attached). Please allow sufficient time for mailed comments to be received before the close of the comment period.

You may write your own letter or use all or as much of the attached sample letter as you like.

If you have any questions please contact APTA’s Federal Regulatory Affairs Department by phone (800-999-2782 ext. 8511) or by email (

Thank you to the APTA for sharing this with its members and we hope we can work together to protect our future.

The CA PPG Board of Directors 

**The California Private Practice Group is a special interest group of the California Physical Therapy Association.

Reimbursement Changes


On June 25, 2010 the Centers for Medicare and Medicaid Services (CMS) released the proposed 2011 Medicare fee schedule and revised payment policies.


1.  41% reduction in reimbursement

  • 23.5% reduction to update sustainable growth
  • 12% reduction by combining OT, PT, SLP and paying 100% of the most expensive code on that day and 50% on all subsequent codes
  • 6.1% fee schedule reduction at the beginning of the year

2.  Change in the way you do business?

  • Discontinue treating patients with Medicare?
  • Take a personal pay cut to stay in business?
  • Never allow OT, PT, SLP to see patients on the same day?

3.  Click here to see full positions from ASHT, AOTA and APTA or for additional details on the proposed CMS 2011 Medicare fee schedule.


1.  Write a letter explaining your concerns including the impact the proposed changes will have on you and your clients. Click here for a sample letter and instructions on how to submit your comments.

2.  Encourage others to write letters. Patient and physician support is very important to this effort. The public will have until August 24, 2010 to submit comments in response to this rule. Please encourage patients and referring physicians to complete and send a sample letter.

Click here for sample patient letter

Click here for sample physician letter

American Society of Hand Therapists
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