"Physical therapy is not a subspecialty of the medical profession and physical therapists are not medical doctors; we are a separate profession that provides a unique service that physicians are unable and untrained to provide."

Letter to the AMA from the APTA, Dec 2009

Friday, July 30, 2010

A Sample Letter from a Private Practice Physical Therapist to Dr. Donald Berwick

...thanks to Melissa Manzione and a well-timed e-mail blast from the American Physical Therapy Association (APTA). Any credit for the value of this post goes to them. The errors are my own.

Dr. Donald Berwick
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1503–P
P.O. Box 8013
Baltimore, MD 21244–8013.

Re: Medicare Program; Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2011. (CMS-1503-P)

Dear Dr. Berwick,

I live and work in Florida where about 70% of my patients are on Medicare. I own and work in a private practice in the outpatient setting where our primary interventions are...
  • preventing falls in the elderly
  • preventing other future adverse events predicted by current findings
  • preventing or reducing institutionalization by improving physical strength and function
  • and providing an alternative to expensive and risky surgeries.

I am greatly concerned about the recent proposed changes to the Medicare Physician Fee Schedule published in the June 25th Federal Register and due to go into effect January 1, 2011. Specifically, these changes affect outpatient physical therapists by recommending a proposed Multiple Procedure Payment Policy (MPPR) that reduces my reimbursement by 50% for each procedure after the first billed in the same day. Typically, physical therapists bill 4 procedures per day, in my setting.

In my community, Medicare is the fastest insurance payer with the highest profit margin. Medicare allows me to subsidize physical therapy services for many of the working class Americans with commericial insurance that pays at or below cost reimbusement to physical therapists in my setting.

This policy is ill concieved and unfounded based on the following points
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 American Medical Association’s (AMA) Resource Based Relative Value System (RBRVS) 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

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.

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.
America needs to reduce healthcare cost growth but these policy changes threaten to INCREASE costs if more Americans are institutionalized, suffer falls or increased disablement or received inappropriate surgery as a result of reduced access to physical therapy.

I urge you to reconsider your proposed physical therapy MPPR policy change in the interest of preserving Americans´independence, reducing costs and building a better healthcare system for the future.

Thank you for your consideration,


Tim Richardson, PT

You can post your letter to Dr. Donald Berwick using the snail mail address in the heading above or you can send your letter electronically to this link:


The comment period deadline is August 24th.

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Tim Richardson, PT owns a private practice at Medical Arts Rehabilitation, Inc in Palmetto, Florida. The clinic website is at MedicalArtsRehab.com.

Bulletproof Expert Systems: Clinical Decision Support for Physical Therapists in the Outpatient Setting is a manager's workbook with stories, checklists, charts, graphs, tables, and templates describing how you can use paper-based or computerized tools to improve your clinic's Medicare compliance, process adherence and patient outcomes.

Tim has implemented a computerized Clinical Decision Support (CDS) system in his clinic since 2006 that serves as a Reminder, Alerting, Prompting and Predicting CDS using evidence-based tests and measures.

Tim can be reached at
TimRichPT@BulletproofPT.com .

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Consistent with the American Physical Therapy Association Vision Statement for Physical Therapy 2020, the American Physical Therapy Association supports exclusive physical therapist ownership and operation of physical therapy services.