APTQI Urges CMS to Stop Harmful Payment Cuts, Allow PTs to Utilize Telehealth-based Care Beyond Public Health Emergency

In a formal comment letter to CMS, APTQI urged the agency to reverse course on severe cuts scheduled to impact physical and occupational therapists on January 1

Washington, D.C. –– The Alliance for Physical Therapy Quality and Innovation (APTQI) sent a formal comment letter to the Centers for Medicare and Medicaid Services (CMS) urging the agency to reverse course on a planned 9% cut to physical and occupational therapy services included in the Proposed Physician Fee Schedule Rule for CY2021. 

“As this letter makes clear, the impact of imposing severe Medicare cuts on outpatient therapy providers in the middle of a public health emergency would be staggering, unprecedented, and detrimental to the millions of Medicare beneficiaries who rely on our services to stay healthy and independent,” said Nikesh Patel, PT, Executive Director of APTQI. “In the strongest possible terms, we urge CMS to reverse course and protect specialty providers like physical and occupational therapists before these draconian cuts can take effect.” 

In August, CMS issued its proposed Physician Fee Schedule rule for 2021, which solidified Medicare’s plans to dramatically reduce payments for more than 30 types of specialty providers. Despite opposition from a broad coalition of healthcare stakeholders, patients, and lawmakers from both parties, the cuts are scheduled to take effect on January 1. To preserve patient access to specialty care and prevent a migration of patients to higher cost sites-of-service, APTQI urges CMS to undo these severe cuts by waiving budget neutrality under the physician fee schedule for 2021.

While recognizing that CMS’ proposed cuts were an attempt to stay within the budget neutrality provisions under Section 1848 of the Social Security Act, APTQI asserted that the deep reimbursement reductions during the COVID-19 pandemic would have a negative impact on pain management services and senior injuries incurred by accidental falls. As the letter notes, “With fall deaths increasing every year, undermining beneficiary access to fall prevention treatments offered by physical therapy is both short sighted and financially ill-advised.”

“The effect of these reductions at a time when many therapy practices have not fully recovered from the business impact of the pandemic is that access to outpatient physical therapy will be compromised. This is especially true for patients living in rural and underserved areas,” added Patel. 

Beyond reversing the proposed payment cuts to specialty care, APTQI also outlined a series of additional comments for CMS to consider, including: 

• Permanently including therapy service procedures in the list of covered telehealth services. While acknowledging that physical therapists are not currently eligible by statute to furnish and bill for telehealth services under Medicare, the letter highlighted the fact that telehealth-based physical therapy services have safely and effectively been provided to Medicare beneficiaries via telehealth since they were authorized under the Public Health Emergency. By including these services in the list of covered telehealth services, it would obviate the need to add them in the future if therapists become eligible telehealth providers under the Medicare program.  

• Finalize rule allowing therapist assistants to furnish maintenance therapy in Part B settings. Noting that physical therapist assistants are qualified providers in the Medicare program who work under the supervision of physical therapists, APTQI urged CMS to finalize its proposed rule removing restrictions that limit the ability of therapy assistants to furnish maintenance therapy in the Part B setting. 

• Classify CPT codes 20560 and 20561 as covered services eligible to be furnished by physical therapists. Asserting support for updating PT codes 20560 and 20561 to active payment status, APTQI urged CMS to also classify dry needling as a covered service and allow for Medicare Administrative Contractors to provide coverage for these services. As the letter notes, “Dry needling is within the scope of physical therapy practice in over 30 states and has been used by therapists for over 30 years…by classifying dry needling as a covered service, CMS would be providing Medicare beneficiaries another safe, yet effective option to alleviate their pain while sparing them from needing to utilize potentially dangerous opioids.”

• Allow for a Certified Plan of Care OR a referral from a Physician/NPP to meet the requirement for coverage and payment of a therapy claim for outpatient therapy services. Pointing to CMS’s long standing objective to “put patients over paperwork,” APTQI urged the agency to change the plan of care certification requirements for outpatient therapy services. Under current regulations, when a patient is referred to a physical therapist by his or her physician, the physical therapist must receive “approval” for the patient’s plan of care from the referring physician in order to begin treatment. This, as the letter notes, creates unnecessary administrative burdens since “the therapist must send the plan of care back to the referring physician to get another signature on the same patient for the same diagnosis in order to meet the requirement for coverage and payment.” By allowing a therapist to use a physician referral (if one is available) to meet coverage requirements outlined by Medicare, CMS would enable physical therapists to focus more time on improving the treatment outcomes of patients. 

To read the full comment letter, click here. 

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