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MPPR reductionsOctober 7, 2021

PROGRESSIVE SELECT INSURANCE COMPANY vs HEAD TO TOE POSTURE REHAB, LLC a/a/o ALIX LOUIS , No. 4D21-647 (Fla. 4th DCA 2021)

Leave it to Progressive. Nobody else in Florida PIP reduces chiropractor bills based upon the concept of MPPR. You know why? It is simple. Medicare does not pay for chiropractor services. Therefore, how do you legislate a payment methodology pursuant to the Medicare fee schedule for a service that Medicare does not recognize? The 4th DCA found a way, of course.

“We therefore conclude that section 627.736(5)(a)3.’s plain language authorizes utilization of MPPR to limit PIP reimbursement for therapy services provided by a licensed chiropractor even though reimbursement to a chiropractor for those same services would not be provided at all under Medicare. Because the trial court concluded otherwise, we reverse the final summary judgment entered in the provider’s favor and remand with instructions for the trial court to enter final summary judgment in favor of the insurer consistent with this opinion”

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