[Editor’s Note: Response to CMS about the proposed PFS has been strong, and the more comments CMS receives the more likely they are to consider our recommendations. Use this prewritten template letter to add your voice by the September 27 deadline and strengthen our message even more.]

In this review: APTA's response to a CMS plan to cut Medicare physician fee schedule (PFS) reimbursement for physical therapy providers by 8% beginning in 2021. The reduction for 2021 is included in the proposed 2020 PFS.

Proposed 2020 Physician Fee Schedule (see table 111, p 1187)

CMS Fact Sheet

CMS press release

The big picture: a proposed 8% cut in Medicare reimbursement for physical therapy providers in 2021

Deep within the proposed 2020 PFS, CMS reveals a plan that puts Medicare beneficiary access to physical therapy at risk by way of an estimated 8% cut to fee schedule reimbursement in 2021. CMS says the reductions, which affect multiple providers to different extents, are driven by changes to reimbursement formulas for evaluation and management (E/M) services furnished by physicians and some other providers.

APTA's message to CMS: significant cuts to fee schedule reimbursement for physical therapy providers will put challenging and likely unsustainable financial pressures on physical therapists (PTs), particularly in rural and underserved areas where access is already limited. As more PTs feel this pressure and opt out of treating Medicare beneficiaries—or close their doors altogether—patient access to care will suffer.

"The changes to reimbursement for office/outpatient E/M codes itself are positive ones and we fully support access to primary care services, but the idea that these changes must be accompanied by deep cuts to other crucial services is outrageous," said Kara Gainer, APTA's director of regulatory affairs. "At a time when our aging population is in need of greater access to physical therapy, with its proven benefits and track record for reducing overall costs, CMS has instead decided to turn its back on the facts and put patients at risk."

What we're doing—and what you can do (before September 27)

We're preparing a formal comment letter to CMS, but that's just a part of APTA's efforts. Because the proposal affects multiple providers, from PTs and occupational therapists to clinical social workers, clinical psychologists, ophthalmologists, optometrists, and chiropractors, we're circulating a provider organization sign-on letter objecting to the cuts, and we're working with the American Occupational Therapy Association to develop an additional sign-on letter to be circulated among members of Congress.

Even more important, we're urging APTA members to bring their individual voices to bear on this issue. We've created a customizable template letter that makes it easy to let CMS know how these proposed cuts will pose a real danger to Medicare beneficiaries and negatively impact PTs' ability to practice under Medicare. Make sure you get your comments to CMS by the September 27 deadline (the template letter includes instructions on how to submit to CMS).

Tip: this letter is the second template letter we've created in response to the 2020 PFS. The first addresses the problematic physical therapist assistant/occupational therapy assistant coding modifier plan, and is still available for download. If you haven't yet completed and submitted that letter, you can combine it with the letter on the reimbursement cuts.

What's next

Deadline for comments is September 27, and the final rule will likely be issued by November 1. In addition to the sign-on letters described above, APTA and several other provider associations will meet with CMS officials in mid-September to share concerns and provide recommendations on a range of issues related to the PFS.