It’s that time of year when CMS proposes changes for 2026 to the Medicare Physician Fee Schedule (MPFS) to adjust payment rates and policies and propose modifications to the Quality Payment Program. 

Here are some of the issues you may want to address but please modify them to fit your practice. CMS does NOT want canned responses. 

Here’s a summary of the key points to consider including in your comments:

Re-evaluate RVU methodology and correct misapplication of efficiency adjustments. The proposed changes to how therapy services are valued (RVUs) may result in lower payments even with a higher conversion factor.  

Include PTs and OTs in the low back pain alternative payment model. Physical therapists are not included in the proposed low back pain care model, even though we are often the first line of treatment for these conditions. 

Extend and make permanent telehealth access for therapy providers. Support CMS’s proposal to eliminate the distinction between provisional and permanent telehealth codes, which would secure long-term access to telehealth for therapy services. Also urge CMS to work with Congress to extend telehealth privileges for therapists beyond the current expiration date of 9/30/2025.

Reconsider RTM code valuations based on RUC recommendations. Appreciate the addition of new RTM codes supporting shorter monitoring periods and reduced clinical time. However, CMS’s proposal undervalues these services by declining the RUC’s recommended relative value units.

Advocate for lasting reforms to the conversion factor to stabilize therapy reimbursement. CMS should back legislation like H.R. 879, which calls for a permanent annual update to the conversion factor based on the Medicare Economic Index (MEI). Additionally, CMS should support efforts to repeal the Multiple Procedure Payment Reduction (MPPR) applied to “always therapy” codes.

Recognize therapy’s role in chronic disease management and quality measurement pathways. Physical and occupational therapists in outpatient private practice are uniquely positioned to improve chronic disease management and prevention. Expand coverage to include intensive lifestyle interventions, chronic disease self-management coaching, and technology-based tools like digital therapeutics would enable therapists to further enhance outcomes for Medicare beneficiaries. 

Make the QPP easier and more cost effective for therapists to participate in. Therapy providers are excluded from value-based incentives. Therapists do not qualify for APM participation but are still subject to the lower conversion factor, creating an unfair gap between physicians and non-physician providers. MIPS is too complex and costly.  The administrative burden and lack of therapy-specific models make it nearly impossible for small practices to participate meaningfully, and the technology requirements are unrealistic. 

We urge you to make your voice heard with CMS on these proposals.  To do that, you will click on the link below which will take you to the CMS form to fill out not later than September 12. THANK YOU! https://www.regulations.gov/docket/CMS-2025-0304