APTA comments on federal regulations and draft guidance based on the Public Policy Priorities of the American Physical Therapy Association, established every 2 years with extensive input from members. APTA's comments are made on behalf of the membership and the physical therapy profession as a whole. However, there is strength in numbers, and if you or your practice may be impacted by a proposed regulation, you also can share your individual comments with the agency to make your voice heard. We encourage members and nonmembers to provide their individual feedback, as these perspectives are critical to policy development. Keep in mind that your comments do not represent the association; they represent you as an individual physical therapist, physical therapist assistant, or student. See "APTA's Current Regulatory Advocacy Efforts" below to see which issues the association currently is addressing.
There are also issues that fall outside of our public policy priorities, and we encourage physical therapists, physical therapist assistants, and students to provide their individual feedback on any of those issues that affect you. Browse the proposed regulations and policies listed under "Additional Regulatory Advocacy Opportunities" that may apply to you.
APTA's Current Regulatory Advocacy Efforts
APTA staff are currently reviewing and submitting comment on the following proposed regulations. If you wish to submit individual comments, click the applicable proposal and use the Regulatory Advocacy Template Letter as a guide.
- CMS 2021 Medicare Advantage proposed rule: The Centers for Medicare and Medicaid Services (CMS) proposed rule would revise regulations for Medicare Advantage (Part C), Medicare Prescription Drug Benefit (Part D), Medicaid, Medicare Cost Plan, and Programs of All-Inclusive Care for the Elderly to implement certain sections of the Bipartisan Budget Act of 2018, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, and the 21st Century Cures Act. The proposed rule would also enhance the Part C and D programs, codify several existing CMS policies, and implement other technical changes. APTA will submit comments related to cost sharing, medical loss ratio, network adequacy, telehealth, and more, and encourages individuals to consider submitting comments using APTA's generic template letter. Review proposed rule.
Deadline to submit comments: Monday, April 6, 2020.
Take Action Now: Submit comments electronically via regulations.gov | Access generic template letter (.doc)
Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency: The CMS interim final rule adds PT, OT, and SLP CPT codes to the list of services covered under the Medicare Physician Fee Schedule when furnished as telehealth, but it did not expand the types of providers eligible to furnish telehealth services to include PTs, OTs, and SLPs. This means PTs are still ineligible to bill Medicare for telehealth services. However, Section 3703 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act grants CMS the authority to add providers to that list. APTA has submitted comments calling on CMS to add physical therapists to the list of authorized telehealth providers, and we encourage individuals to consider submitting comments using APTA’s unique template letter. Review proposed rule.
Deadline to submit comments: June 1, 2020.
Take Action Now: Submit comments electronically here | Access unique template letter (.doc)
Additional Regulatory Advocacy Opportunities
Below are proposed regulations and guidance that fall outside APTA's public policy priorities but may have an impact on you and your practice. If you wish to submit individual comments to an agency, follow the submission instructions provided in the proposed regulation and use the Regulatory Advocacy Template Letter as a guide.
- Opportunities for to send a comment letter to your representative will be posted here as they become available. Check back frequently for updates.
Regulatory Advocacy Template Letter
APTA has created this template letter for you to use in submitting comments. Simply insert your individual information where indicated. As a reminder, your comments represent only you and your situation; they should not imply representation of the association. Access template letter (.doc).
Other Ways to Engage
Federal agencies frequently seek input from stakeholders and national experts on proposed payment and coverage policies, research agendas, quality measures, and more. The selection process for federal committees, task forces, panels, and commissions is competitive. Participation in these groups demonstrates both expertise in your field and a commitment to your profession, which will be reflected on your CV for years to come. Serving on such a committee allows you to make invaluable contributions to your area of expertise and raise recognition of the physical therapy profession. While serving requires a small time commitment, the time is well spent and is a great way to develop networks and make contacts with fellow experts from across the nation.
If you are interested in serving on a federal committee, task force, or advisory panel, please contact the advocacy team at firstname.lastname@example.org and provide your name, contact information, and a brief biographical sketch.