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MPPR reductions
No-Fault

MPPR reductions

By Jason Tenenbaum 8 min read

Key Takeaway

Florida's 4th DCA ruled Progressive can apply Medicare's MPPR reductions to chiropractor bills despite Medicare not covering chiropractic services at all.

Understanding Medicare’s Multiple Procedure Payment Reduction (MPPR) rules is crucial for healthcare providers dealing with insurance reimbursements. MPPR is designed to reduce payments when multiple therapy services are provided on the same day, reflecting Medicare’s belief that certain efficiencies should reduce overall costs. However, a recent Florida decision creates a puzzling situation: applying Medicare payment reductions to services that Medicare doesn’t even cover.

This case highlights the ongoing challenges in New York No-Fault Insurance Law and similar state systems, where insurance companies continuously seek new ways to limit reimbursements to healthcare providers. The ruling demonstrates how insurance carriers can exploit gaps in legislative language to their advantage, even when the underlying logic seems contradictory.

Jason Tenenbaum’s Analysis:

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”

Key Takeaway

This Florida appellate decision allows Progressive to apply Medicare’s Multiple Procedure Payment Reduction to chiropractor services, despite Medicare not covering chiropractic care. The court’s interpretation of statutory language prioritizes the insurer’s cost-cutting measures over logical consistency, potentially setting a concerning precedent for healthcare provider reimbursements in no-fault insurance systems.

Common Questions

Frequently Asked Questions

What is New York's no-fault insurance system?

New York's no-fault insurance system requires all drivers to carry Personal Injury Protection (PIP) coverage. This pays for medical expenses and lost wages regardless of who caused the accident, up to policy limits. However, you can only sue for additional damages if you meet the 'serious injury' threshold.

Filed under: No-Fault
Jason Tenenbaum, Personal Injury Attorney serving Long Island, Nassau County and Suffolk County

About the Author

Jason Tenenbaum

Jason Tenenbaum is a personal injury attorney serving Long Island, Nassau & Suffolk Counties, and New York City. Admitted to practice in NY, NJ, FL, TX, GA, MI, and Federal courts, Jason is one of the few attorneys who writes his own appeals and tries his own cases. Since 2002, he has authored over 2,353 articles on no-fault insurance law, personal injury, and employment law — a resource other attorneys rely on to stay current on New York appellate decisions.

Education
Syracuse University College of Law
Experience
24+ Years
Articles
2,353+ Published
Licensed In
7 States + Federal

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