This year's Medicare Physician Fee Schedule includes proposed changes that would improve occupational therapy (OT) reimbursement under Medicare Part B. At the same time, the Centers for Medicare & Medicaid Services (CMS) is also considering policies that could affect beneficiary access to OT services now, and impact opportunities for OT practitioners in the future. CMS is specifically asking for feedback, and YOUR experiences can help shape their final policy decisions.

We encourage OT practitioners to comment on the issues that most directly affect their practice. Whether you have experienced the impact of ongoing Medicare payment reductions and need the proposed increase, provide caregiver training, use Remote Therapeutic Monitoring (RTM), or help clients achieve health and wellness goals through behavior change and self-management strategies, your voice can help ensure Medicare policies support access to high-quality occupational therapy services.

Some Priority Issues for Comment Consideration

The most effective comments are personal. Tell CMS how these policies affect your patients, your practice, and your ability to deliver occupational therapy services. Real-world examples help demonstrate the value of OT and ensure Medicare policies support access, function, health, and independence for Medicare’s beneficiaries.

Support CMS's Practice Expense Reforms

CMS is proposing to remove the Indirect Practice Cost Index (IPCI) from its practice expense methodology. AOTA's analysis suggests this change is a major factor in the projected increase in OT relative value units (RVUs) for 2027. This is the first CMS policy to lead to a significant positive adjustment to OT valuation in many years. The IPCI is a longstanding component of CMS’s practice expense methodology that has historically disadvantaged OT and other lower-practice-expense professions. AOTA has highlighted issues with the IPCI to CMS and its removal represents an important step toward a more equitable payment system for occupational therapy.

Tell CMS:

• You support eliminating the IPCI and appreciate CMS taking steps to improve the valuation of OT services.
• Explain how years of Medicare payment instability and reimbursement reductions have affected patient access, your practice, and your ability to invest in staff, services, and technology. Share how this policy, and the improvement in OT valuation is important to maintaining beneficiary access to OT services

Protect and Strengthen Caregiver Training Services (CTS)

CMS is seeking feedback on whether Caregiver Training Services (CTS) should continue as distinct Medicare services or whether the resources associated with caregiver training are already reflected in other services, such as Evaluation and Management (E/M) visits. Because OT practitioners generally cannot bill E/M services, changes in this area could affect access to caregiver training provided by therapy professionals. CMS also did not address AOTA’s longstanding concerns related to Medicare's caregiver training billing requirements, which require practitioners to furnish the complete billing increment before reporting the service and often do not reflect how caregiver training is delivered in real-world practice. 

Tell CMS:

• Caregiver training should remain a separately recognized and reimbursed service.
• Medicare should address existing billing barriers that limit use of caregiver training codes.

Share examples of how caregiver training without the client present can improve safety, reduce caregiver burden, and support successful discharge home.

Recognize OT's Role in Health and Well-Being Coaching

CMS is proposing payment for new health and well-being coaching services that focus on behavior change, goal setting, self-management, and long-term health improvement. These services closely align with the knowledge and skills occupational therapy practitioners use every day to help clients develop healthy habits, manage chronic conditions, and achieve meaningful health goals. However, CMS has not proposed recognizing occupational therapy practitioners as qualified providers of these services based on their existing licensure, education, and training. Instead, CMS is proposing to require specific health coaching certifications for individuals furnishing and reporting these services.

Tell CMS:

• OT practitioners should be recognized as qualified providers of health and well-being coaching services.

Highlight OT practitioners’ extensive education and experience in behavior change, habit formation, chronic disease management, health promotion, and helping individuals achieve meaningful health goals. Explain how Medicare beneficiaries would benefit from greater access to the services through OT.

Ensure RTM Policies Preserve Patient Access

CMS is proposing several changes to Remote Therapeutic Monitoring (RTM), including requiring RTM services to be furnished only to established patients and limiting the use of certain third-party staffing arrangements. While CMS intends these changes to address program integrity concerns, they could affect how RTM services are implemented and delivered. CMS is specifically seeking feedback on how these proposals could impact patient access and provider operations.

Tell CMS:

• You support policies that preserve beneficiary access to RTM and allow OT practitioners flexibility in implementing RTM services while ensuring appropriate clinical oversight and program integrity.
• Describe how RTM is used in your practice to support patient engagement, treatment adherence, monitoring, and clinical decision-making. Explain how the proposed restrictions could affect workflows, staffing models, and beneficiary access to RTM services. Share examples of how RTM has improved outcomes or enhanced delivery of OT services.

How to Submit Comments 

Step-by-Step Instructions 

Make sure you are comfortable with the issue you are commenting on: 

• Familiarize yourself with CMS’s proposals and information requests by reading AOTA’s summary articles on the CY 2027 MPFS payment and MIPS proposals.

Prepare your letter: 

• Address the letter to Administrator Oz and reference file code “CMS-1848-P”
• Please customize your letter. CMS needs to hear from individuals who will be affected by these policies. We are asking you to write your own letter because a short letter from you explaining the impact is more powerful than a form letter.
• Keep it professional and focus on the policy impact. We suggest focusing on beneficiary access, sustainability of the workforce, and why access to OT is important.
• Do not include personal information such as phone number, email or address in the letter.

Submit the Comment Letter: 

• Go to the 2027 MPFS Proposed Rule in the Federal Register.
• Click on the green box that says, “Submit a Public Comment”.
• Paste your letter into the comment field or upload a PDF under “add file”.
• You will be asked for more information at the bottom of the form, including name and email.

Deadline 

• All comments are due by 5:00 pm ET, September 14, 2026.