ACT NOW: CMS needs to hear from physical, occupational, and speech therapists like you on this proposed rule before the comment period closes on September 12 at 11:59pm Eastern time!
It’s that time of year when CMS proposes changes for 2026 to the Medicare Physician Fee Schedule (MPFS) to adjust payment rates and policies and propose modifications to the Quality Payment Program.
Here are some of the issues you may want to address, but please modify them to fit your practice. CMS does NOT want canned responses. To start, please give a brief description of who you are, years of experience, specialty, and how this proposed rule would affect your practice.
WHAT TO COMMENT:
Here’s a summary of the key points to consider including in your comments (for more detail, scroll down):
- Re-evaluate RVU methodology and correct misapplication of efficiency adjustments.
- Include PTs and OTs in the low back pain alternative payment model.
- Extend and make permanent telehealth access for therapy providers.
- Reconsider RTM code valuations based on RUC recommendations.
- Advocate for lasting reforms to the conversion factor to stabilize therapy reimbursement.
- Recognize therapy’s role in chronic disease management and quality measurement pathways.
- Make the QPP easier and more cost-effective for therapists to participate in.
- Reduce the administrative burden on small private practices.
HOW TO COMMENT:
The proposed rule includes directions for submitting comments. CMS must receive comments within the 60-day comment period, which closes on September 12 at 11:59pm Eastern time. When commenting, refer to file code: CMS-1832-P. CMS won’t accept fax transmissions.
Use one of the 3 following ways to officially submit your comments:
- Electronically: https://www.regulations.gov/docket/CMS-2025-0304. Follow the “Submit a comment” instructions. Due no later than 11:59 pm ET on September 12, 2025.
- Regular mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, P.O. Box 8016, Baltimore, MD 21244-8016. Due no later than 5:00 pm ET on September 12, 2025. Please allow sufficient time for mailed comments to be received before the close of the comment period.
- Express or overnight mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850. Due no later than 5:00 pm ET on September 12, 2025.
Here’s more detail on the key topics to discuss:
1. Conversion factor and RVUs – The proposed 3.3% increase to the conversion factor for non-qualifying Alternative Payment Model (APM) participants is effectively nullified by unjustified adjustments to RVUs for Physical Medicine & Rehabilitation (PM&R) codes. The proposed “efficiency adjustment” to work RVUs intended for non-time-based codes has been erroneously applied to numerous timed PM&R codes. This is a clear mistake that must be corrected.
Timed codes are already subject to the Multiple Procedure Payment Reduction (MPPR), and applying an additional efficiency cut is duplicative and unjustified. Furthermore, changes to practice expense and professional liability RVUs found only in the addenda and not explained in the rule’s text are deeply concerning. These codes have recently undergone review by the Relative Value Update Committee, and further reductions lack transparency and rationale.
The cumulative impact of these changes threatens to offset any benefit from the conversion factor increase. Urge CMS to appropriately value physical therapy services by removing the efficiency adjustment from time-based codes and provide clear justification for any RVU modifications.
To put it simply: The proposed changes to how therapy services are valued (RVUs) may result in lower payments even with a higher conversion factor. This could make it harder for clinics to continue serving patients, especially in underserved areas.
2. Alternative Payment Model for Low Back Pain – Support CMS’s initiative to develop a mandatory alternative payment model focused on low back pain and congestive heart failure to improve quality and reduce costs. However, excluding physical and occupational therapists from participation overlooks our critical role in conservative musculoskeletal care. These decisions contradict CMS’s stated goals of promoting prevention and chronic disease management, areas where physical and occupational therapy plays a critical and evidence-based role. Moreover, the bifurcation of conversion factors, offering a higher rate to qualified APM participants while leaving most physical therapists with a lower increase, creates a disparity that penalizes providers who are already stretched thin and often lack the infrastructure to participate in complex alternative payment models.
Request that CMS includes outpatient therapy providers as eligible participants to optimize patient outcomes and support non-pharmacologic management strategies.
To put it simply: Physical therapists are not included in the proposed low back pain care model, even though we are often the first line of treatment for these conditions. It is imperative that PT is included in this model.
3. Payment for Medicare Telehealth Services Under Section 1834(m) of the Social Security Act – Therapy services are currently listed as Category 3 Medicare Telehealth Services temporarily through September 30, 2025. Support CMS’s proposal to eliminate the distinction between provisional and permanent telehealth codes, which would secure long-term access to telehealth for therapy services. However, urge CMS to work with Congress to extend telehealth privileges for Physical Therapists, Physical Therapy Assistants, and Occupational Therapists, and Occupational Therapy Assistants beyond the current expiration date. Congress must extend permanent telehealth privileges to physical and occupational therapists to promote prevention, accessibility, efficiency of health care delivery, support chronic care, and equity of health care. Urge CMS to expand the definition of telehealth practitioners to include qualified physical therapists, occupational therapists, speech-language pathologists, and audiologists and to make their services permanent under Category 1 or 2. Provisional codes frequently used by therapists such as 97110, 97112, 97116, 97161, 97162, 97163, 97164, 97530, and 97535, should all be made permanent, not only those for caregiver training.
While CMS lacks the authority to amend the definition of distant-site providers, Congress can, through legislation, namely H.R. 2263 and H.R. 1614, to permanently allow rehabilitation therapists and their assistants to provide care via telehealth. Urges CMS to support these legislative efforts.
Telehealth has become a vital part of health care delivery for Medicare beneficiaries nationwide, not just those in rural or underserved areas, and must remain accessible permanently.
To put it simply: There are many patients who rely on physical and occupational therapy services via telehealth for continuity of care. It is very important to allow physical therapists, physical therapy assistants, and occupational therapists and occupational therapy assistants to continue to be allowed to provide telehealth services beyond the September 30th cut off. Permanent telehealth privileges for these disciplines would allow for patients to continue to have access to the vital care they need.
4. Remote Therapeutic Monitoring (RTM) – Appreciate the addition of new RTM codes supporting shorter monitoring periods and reduced clinical time. However, CMS’s proposal undervalues these services by declining the RUC’s recommended relative value units. Given the growing use of RTM in outpatient practice to support patient adherence and outcomes, appropriate valuation is critical.
5. Advocate for lasting reforms to the conversion factor to stabilize therapy reimbursement – The current conversion factor system frequently undergoes budget neutrality adjustments and short-term congressional fixes, causing payment instability. Since 2001, Medicare physician payments, after adjusting for practice costs, have effectively dropped by 33% and have not kept pace with inflation. To address this, CMS should back legislation like H.R. 879, which calls for a permanent annual update to the conversion factor based on the Medicare Economic Index (MEI). Additionally, CMS should support efforts to repeal the Multiple Procedure Payment Reduction (MPPR) applied to “always therapy” codes, as these reductions are unnecessary and overly harsh. These reforms are essential first steps toward creating more stable payment systems for providers. Furthermore, CMS should create opportunities for physical and occupational therapists in private practice to join Medicare-focused value-based care programs that reward performance, outcomes, and patient satisfaction.
6. Role of Physical and Occupational Therapists in Chronic Disease Management and Prevention – Physical and occupational therapists in outpatient private practice are uniquely positioned to improve chronic disease management and prevention through holistic, patient-centered care extending beyond currently reimbursable services. Physical and occupational therapy are not only rehabilitative, but also preventive, restorative, and essential to optimizing health outcomes for Medicare beneficiaries.
Outpatient therapy providers provide vital interventions addressing root causes and functional impacts of chronic illnesses, including:
- Movement and Exercise Prescription: Individualized plans improve cardiovascular health, enhance metabolic function, and reduce risk factors for diseases such as diabetes, hypertension, and obesity—supporting prevention and long-term health.
- Lifestyle Modification and Education: Education on healthy behaviors, nutrition, and stress management empowers patients to actively manage their health and prevent exacerbation.
- Functional and Environmental Assessments: Assessing patients’ environments to identify barriers and recommend adaptive strategies promotes sustained engagement in wellness.
- Chronic Pain and Symptom Management: Non-pharmacologic approaches reduce pain and improve function in musculoskeletal and neurological conditions, decreasing medication reliance.
- Behavioral Health Integration: Routine screening for depression, anxiety, and cognitive impairment facilitates referrals and addresses psychosocial contributors to chronic disease.
Despite these critical contributions, many prevention-focused services remain unreimbursed under Medicare’s current fee schedules. Expanding coverage to include intensive lifestyle interventions, chronic disease self-management coaching, and technology-based tools like digital therapeutics would enable therapists to further enhance outcomes for Medicare beneficiaries.
Encourage CMS to consider these factors in developing new codes and payment mechanisms to better support chronic disease prevention and management within outpatient therapy.
7. Quality Payment Program and Merit-based Incentive Payment System (MIPS) Value Pathways – The QPP poses significant challenges to non-physician providers, including physical and occupational therapists. Physical and occupational therapists do not qualify for APM participation but remains subject to the lower conversion factor. While CMS is statutorily required to maintain two conversion factors, this policy further separates physicians, who APMs were designed for, from nonphysician providers like therapists, who face significant barriers to participation. Therapists have struggled to meaningfully participate in MIPS or Alternative Payment Models (APMs), partly due to the lack of models designed for therapy providers, high cost and complexity of participation, and the administrative burden outweighs the potential performance-based adjustments. The interoperability requirements are often insurmountable for small and independent therapy practices. Congress must enact reforms that recognize the value of therapy providers and facilitate their meaningful participation.
To put it simply: Therapy providers are excluded from value-based incentives. Therapists do not qualify for APM participation but are still subject to the lower conversion factor, creating an unfair gap between physicians and non-physician providers. MIPS is too complex and costly. The administrative burden and lack of therapy-specific models make it nearly impossible for small practices to participate meaningfully, and the technology requirements are unrealistic.
8. Reduce the administrative burden on small private practices – Small therapy practices participating in Medicare face significant challenges in managing the extensive administrative requirements placed on them. These processes are often cumbersome, complex, and inefficient at every stage. For instance, CMS should explore ways to streamline documentation, billing, coding, prior authorization, and claims submission. Additionally, funding support for affordable billing and EMR/EHR systems is essential to reduce administrative workload, simplify quality reporting, and facilitate easier data submission. Easing these burdens will enable therapists to devote more time to patient care, improve the financial viability of their practices, encourage greater participation in Medicare, and ultimately expand access to therapy services for beneficiaries.
Thank you for taking the time to send CMS your comments! Together we can make a difference.