APTA Invited to Inform Key Congressional Caucus on Medicare Payment Reform

In response to an invitation to submit comments to the Congressional Doctors Caucus, APTA submitted extensive comments outlining the current payment challenges faced by physical therapists under the Medicare Physician Fee Schedule. APTA's recommendations included:

• Reforming the Merit-Based Incentive Payment System, or MIPS, program
• Expanding opportunities for participation in alternative payment models, or APMs
• Increasing transparency and analysis of the CPT coding valuation process

In addition, APTA provided comments on the need for Congress to repeal the problematic policy known as the Multiple Procedure Payment Reduction, or MPPR. The request for information from the Republican and Democratic House Doctors Caucuses - comprised of U.S. House members who are physicians - was sent out to select national health care associations as part of ongoing efforts to reform the physician fee schedule.

APTA's Advocacy to Repeal MPPR

APTA has strongly opposed the MPPR policy since its implementation in 2011. The policy imposes excessive and unnecessary payment reductions on specific "always therapy" codes, significantly impacting the financial viability of therapy practices and limiting access to care. For years, APTA has advocated to the Centers for Medicare & Medicaid Services on the application of MPPR through comments on the fee schedule proposed rule, letters specific to the MPPR policy, and multiple meetings with CMS highlighting the policy's flawed methodology and impact. These efforts by APTA led CMS to acknowledge in the final 2024 fee schedule that duplicative reductions had occurred and to recommend that the RUC, the committee that makes recommendations on the value of each code, reconsider the practice expense valuation for 19 therapy codes.

APTA continues to engage CMS to address inappropriate practice expense reductions for many codes that physical therapists routinely report within the agency's statutory authority. APTA has also been seeking to repeal the MPPR via legislation as part of broader efforts to reform the fee schedule. The comments to the caucus highlighted APTA's model legislation to repeal MPPR and the need to include it in any Medicare reform package.

Alternative Payment Model Options

Also noted in APTA's comment letter is that physical therapists, in particular, have struggled to participate in MIPS or meaningfully engage in APMs. This is in part because CMS has failed to pilot or implement several alternative payment and delivery models applicable to therapy providers, highlighting the need to adopt APTA's recently developed alternative payment model that addresses frailty by incorporating physical therapists into a patient's primary care team.

APTA urged Congress to enact meaningful reforms, including adopting APTA-developed draft legislative language that specifically recognizes the value of therapy providers and ensures effective oversight of the Quality Payment Program to determine its effectiveness in measuring therapy performance and outcomes.

An Annual Payment Update Is Essential for Meaningful Reform

As part of its ongoing advocacy efforts to reform payment, APTA is also supporting legislation that would enact an annual payment update under the fee schedule tied to the Medicare Economic Index. In addition, APTA supports legislation that would address the policy known as budget neutrality, which has triggered year-over-year cuts to providers under Medicare, as well as legislation that would require CMS to update the direct inputs for practice expense relative value units at least every five years to ensure payments keep up with the rising costs of operating a clinic.

Be an Advocate for the Profession

Learn more about some of the bills APTA is advocating for in the 119th Congress.

Medicare payment reform will be one of the issues APTA members will advocate for as part of APTA's Capitol Hill Day on April 19-21 in Washington, D.C. Registration is now open.

Join APTA's Advocacy Network to stay up to date on the latest developments in payment advocacy and how you can help amplify the profession's voice.