McKelvey, Tom--TX

I strongly oppose the provision in the proposed rule that would apply the Multiple Procedure Payment Reduction (MPPR) policy to outpatient therapy services. This policy will lead to significant and unnecessary cuts in reimbursement for therapy services and will jeopardize access to care for Medicare beneficiaries. If implemented, this rule will result in physical therapy clinics closing or refusijng to treat Medicare patients and ultimately to a reduction in the already short supply of physical therapists. While I understand the desire to reduce Medicare costs, the challenge is to do so without reducing the availability or quality of needed care, and the MPPR policy is a misguided and destructive approach. A more effective approach would be to actually figure out how to uncover and prosecute fraudulent billing practices which are rampant in healthcare. I suggest starting by addressing the rapidly increasing practice of physicians billing inappropriately for "physical therapy" services as identified in the 2006 OIG report (attached). If a physician is billing for physical therapy services there is a very good chance that at least some of the billing is inappropriate, and a reasonable chance that it's fraudulent. There are many physical therapists out here working tirelessly to provide necessary and effective services and there are some who are scamming the system. I would be happy to help you identify the scammers and I would recommend cutting their reimbursement by 100%. But to cut payment to all physical therapists with the MPPR policy is irresponsible.