Man holding small dumbbell receiving physical therapy from therapist

The Alliance for Physical Therapy Quality and Innovation (APTQI) called on the Centers for Medicare & Medicaid Services to revisit its Medicare doctor fee proposal for next year, saying the changes could affect access to physical therapy and providers.

The proposed rule would cause “yet another round” of reductions for physical and occupational therapy services in the year ahead, it said.

“As demonstrated in the proposed rule, physical and occupational therapy providers would see a combined impact of negative 3.6%,” APTQI said in a letter sharing feedback on the suggested changes.

The reimbursement rate reduction is particularly a problem because fees haven’t kept pace with inflation, the group says. Previous cuts already negatively affected the field.  

“If finalized, the 3.6% payment cut could put further financial pressure on physical and occupational therapists making it more difficult for them to provide care to Medicare beneficiaries,” an APTQI spokesperson told McKnights. “Lower Medicare reimbursement often makes it harder to attract staff, exacerbating healthcare workforce shortages the country is already experiencing.”

APTQI recommended that CMS delay the implementation of the G2211 code until 2025 when the fee schedule is eligible for inflation adjustments again.Reimbursement cuts would affect patient access to therapy services and the stability of providers, if finalized, APTQI said.

“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. 

In the letter, APTQI also encouraged CMS to allow physical therapy assistants (PTAs) and occupational therapy assistants (OTAs) to practice at the top of their licenses. As it stands, PTAs and OTAs must be directly supervised (by in-person physical therapists, or PTs and occupational therapists, or OTs) in private settings under Medicare. The PT or OT must be physically present. In outpatient settings, the PTAs and OTAs only have to be generally supervised (the PT and OT don’t have to be on-site but available by audio). APTQI says that standardizing supervision requirements across outpatient settings and letting PTAs and OTAs to practice while supervised in private practice settings would lower administrative burdens, enhance access to care and keep Medicare policies with state-level requirements. 

APTQI supported some other provisions in the proposal. It agreed with establishing a general supervision policy for therapy assistants delivering remote therapeutic monitoring (RTM) services in private practice. APTQI also wanted to see clinical labor time entries for 19 therapy codes reviewed again, saying it could address long-standing underpayment issues for therapy services.

APTQI encouraged CMS to allow for a certified plan of care to be presumed certified if the therapist gets a referral from a physician or non-physician practitioner no more than 90 days prior to initiating therapy services, and documented evidence that the plan of care has been delivered to the physician. The group said this could lower the administrative burden and streamline care for people who need services. 

“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,” Nick Patel, executive director of APTQI, said in a statement.