APTQI Opposes Medicare Cuts to Therapy Services in CY 2024 Physician Fee Schedule in Comment Letter to CMS

Washington, DC – In a comment letter submitted on September 11, The Alliance for Physical Therapy Quality and Innovation (APTQI) urged the Centers for Medicare & Medicaid Services (CMS) to revisit its Medicare Physician Fee Schedule Proposed Rule for CY 2024. In the letter to CMS Administrator Chiquita Brooks-LaSure, APTQI detailed concerns about the impact that reimbursement cuts, among other provisions, may have on patient access to therapy services and the stability of providers if finalized.

“Considering the enormity of these cuts, it is clear that physical therapy for Medicare patients is at serious risk. If CMS proceeds with the 2024 and subsequent cuts as proposed, the country will undoubtedly see practice closures and providers opting out of the Medicare program, which would then stifle access to important therapy treatments,” the letter stated.

Specifically, the comment letter expressed deep concern about implementing the G2211 Code, which would result in a combined -3.6% reduction for physical and occupational therapy services, particularly at a time when the Physician Fee Schedule has not kept pace with inflation and previous therapy-specific cuts are already impacting negatively patient access to non-pharmacological treatment options for pain.

APTQI also called on CMS to allow physical therapy assistants (PTAs) and occupational therapy assistants (OTAs) to practice at the top of their license. By standardizing supervision requirements across outpatient settings and allowing PTAs and OTAs to practice under general supervision in private practice settings, it would enhance access to care, reduce administrative burdens, and align Medicare policies with state-level requirements.

APTQI did express support some provisions in the Proposed Rule. First, APTQI endorsed the proposal to establish a general supervision policy for therapy assistants delivering remote therapeutic monitoring (RTM) services in private practice settings. Doing so would facilitate patient access to RTM services while also ensuring patient safety and quality of care. APTQI also endorsed the re-review of clinical labor time entries for 19 therapy codes, which could address long-standing underpayment issues for therapy services.

Finally, APTQI urged CMS to allow for a certified plan of care to be presumed certified if the therapist receives a referral from a physician or NPP no more than 90 days prior to initiating therapy services, and documented evidence that the plan of care has been delivered to the physician. This would help reduce administrative burden and streamline patient care.

“As our country faces both a devastating opioid epidemic and senior falls epidemic, it’s urgently important that older Americans can access physical therapy care. We look forward to continuing to work with CMS officials on the critical issues affecting therapy patients and providers,” said Nick Patel, PT, DPT, Executive Director of APTQI.