Physical Therapy Leaders Submit Medicare Physician Fee Schedule Comment Letter Urging Equipment Price Updates

Warning direct practice expense inputs are outdated, APTQI encourages CMS to take steps to ensure physical therapy services and equipment are appropriately valued

Washington, D.C. – The Alliance for Physical Therapy Quality & Innovation (APTQI) last week submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) regarding calendar year (CY) 2026 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies, encouraging CMS to embrace policies that ensure Medicare beneficiaries maintain access to high-quality, cost-effective physical therapy care.

In a comment letter to CMS Administrator Dr. Mehmet Oz, APTQI highlights several areas where CMS could address in its CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule, including providing updates for long-outdated equipment valuations, removing certain CPT codes from the Efficiency Adjustment list, and providing more transparency about how it calculates indirect practice expenses.

Among its key recommendations, APTQI urges CMS to:

• Update equipment inputs for common therapy codes, many of which have not been revised since at least 2005, to reflect modern safety and technology standards. This includes parallel bars and treadmills, which have become considerably more advanced over the last two decades.
• Remove certain therapy CPT codes from the efficiency adjustment list, emphasizing that many therapy services cannot be done quicker or more efficiently due to human physiology. Moreover, many codes have been re-evaluated over the last few years and further efficiency adjustments risk undervaluing vital therapy services.
• Reevaluate proposed changes to the Indirect Practice Cost Index (IPCI), which includes an unexplained 12.5% reduction of the IPCI for physical therapists in 2026—more than three times higher than the rate of change observed in recent years.
• Finalize the new Remote Therapeutic Monitoring (RTM) codes for Muscular Skeleton Care that CMS included in the proposed rule.
• Provide greater transparency on the impact of payment methodology changes to ensure therapy services are appropriately valued.
• Revise practice expense methodology to recognize the rising cost of medical technology, such as Software and a Service (SaaS) and AI tools, as an essential practice expense.

“APTQI shares the core belief that any proposals related to physical therapy services should (a) drive payment in line with the value physical therapy services deliver to the patient and other providers in the continuum of care; (b) reduce unnecessary regulatory and administrative burdens unrelated to improving the quality of patient care; and (c) be transparent to patients and all stakeholders,” the letter states.

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