CMS Wants Your Feedback: Help Lock In Two Key Wins for the Profession

For another year, the budget-neutral Medicare Physician Fee Schedule has led to proposed payment cuts threatening all clinical specialties paid under the fee schedule, including physical therapy. But there is cause for celebration in the form of two big wins for the profession relating to physical therapist assistant supervision and plan of care requirements - both proposals that APTA has aggressively advocated for. Share your comments by Sept. 9 to bring these two proposals over the finish line.

Make Your Voice Heard

1. PTA General Supervision in Medicare Part B Settings
   The U.S. Centers for Medicare & Medicaid Services is seeking to move from direct to general supervision for PTAs who work in Medicare Part B settings. This would create consistency in the level of supervision required across all Medicare settings.
2. Modifying the Physician Signature Requirement on Plans of Care
   CMS is proposing to allow the physician's signed order or referral to demonstrate the initial certification of the PT's plan of care. Under current rules, the referring provider must sign the plan of care within 30 days of receiving it - or the PT risks not being paid by Medicare. CMS is also asking for comments on whether there should be a deadline for a provider to make changes to the plan of care when there are currently no deadlines.

Two Ways to Help Cement These Changes

1. Use APTA's award-winning comment tool that walks you through writing a personalized letter to share your experiences and how the rule would affect your practice.
2. Or, if you don't have 15 minutes to spare, use APTA's prewritten template letter to quickly send comments to CMS.

Make Your Voice Heard

Want to read or learn more about how the 2025 proposed fee schedule would affect the physical therapy profession and the people you serve?

For more insight on these issues, listen to this APTA Podcast episode with staff experts Andrew Amari, JD, and Rachel Miller, MPH.

Why Member Voices Matter to CMS

We know your voice matters - and CMS knows it, too. CMS' 2025 proposed rule directly quotes some of the feedback submitted by members who used our comment tool last year.

In recent years, CMS has made it clear that a single compelling comment can carry more weight than a thousand identical generic comments, Amari says. (Still, signing your name on a template letter is better than nothing - strength in numbers matters!)

Another reason your voice matters: APTA will be sharing our feedback on the fee schedule in our own comment letter, but it's not possible for us to capture the perspectives of all our members.

"We can cover more ground together, make more compelling arguments together, and show significant investment from our community when it comes to establishing and understanding policy changes," Amari explains.

Now that you know the why, here's the how.

Ready to Start Writing?

APTA's award-winning comment tool has guidance built in, but APTA staff experts have created lots of other resources to help you through this process.

APTA advocacy staff developed seven steps and considerations to help you draft a personalized comment letter. These steps are:

1. Get the facts and understand the issues before commenting.
2. Draft a statement of authority, describing who you are and how your perspective relates to the proposals.
3. Restate the issue and explain what you want the agency to do.
4. Support your positions using your professional perspective.
5. Expand support for your positions using details from your personal experience.
6. Keep it short and sweet; don't feel compelled to write a novel.
7. Express gratitude for positive proposals.

In this five-minute video, Amari walks through the seven steps you can follow to draft a personalized comment letter.

If you want to see examples from fellow APTA members, we've got three examples of submissions from previous years written by:

1. A new PT working in an outpatient orthopedic setting.
2. A PT who doesn't typically see Medicare beneficiaries but still has a valuable perspective to add.
3. A PT with 25 years of experience working in acute and postacute settings.

These articles not only share the PTs' letters but also offer commentary on why these letters are so effective.

Now that you know the what, the why, and the how, you have all the tools you need to submit your own comment letter to CMS.

Make Your Voice Heard

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