Young, Debra--DE

Donald Berwick, M.D. Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS–1503–P P.O. Box 8013 Baltimore, MD 21244–8013 Dear Dr. Berwick: As an occupational therapy practitioner, I have serious concerns regarding the proposed Medicare Physician Fee Schedule rule for 2011, published by the Centers for Medicare & Medicaid Services in the July 13, 2010 Federal Register (CMS-1503-09). CMS proposes a Multiple Procedure Payment Reduction (MPPR) policy for outpatient therapy services that would result in severe payment cuts to medically necessary occupational therapy, physical therapy and speech-language pathology services for Medicare beneficiaries. These cuts are completely arbitrary, and could not come at a worse time. Fee schedule cuts of more than 21.3% due to the sustainable growth rate formula (SGR) will take effect in December absent Congressional action, therapy exceptions to the caps expire in December, and we are already trying to comply with the many other Medicare changes. Deep cuts - estimated by CMS itself to be about 12-13% - at this time of economic hardship threaten my ability to serve Medicare patients and could force occupational therapy practices to consider closing their doors or dropping out of the Medicare program. My clients get better with my therapy. Lastly, the proposed rule does not distinguish between the therapies and reduces practice expense (PE) payments to all when they are provided on the same day. The interventions furnished by and equipment used by occupational therapists are distinct from other therapies. I strongly oppose the proposed MPPR policy based on these significant concerns and urge CMS to withdraw it from the rule. Signed, Debra Young, MEd., OTR/L, ATP, CAPS