APTA comments on federal regulations and draft guidance based on the Public Policy Priorities of the American Physical Therapy Association, established every 2 years with extensive input from members.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 National Correct Coding Initiative (NCCI) Edits: Your comments are needed to address NCCI edits that will limit appropriate care. Effective January 1, 2020, new procedure-to-procedure edits are assigned to CPT codes 97530 and 97150, prohibiting billing of these codes with the physical therapy and occupational therapy evaluation codes. Another new edit requires appending modifier 59 to CPT 97140 when billed with a physical therapy or occupational therapy evaluation. These edits are inconsistent with the edit model, and conflict with current CMS policy. Please send comments to the NCCI contractor, Capitol Bridge, LLC, urging them to remove these edits.
Take Action Now: Submit comments using APTA's unique template letter (.docx) to Capitol Bridge, LLC at: NCCIPTPMUE@cms.hhs.gov
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 email@example.com and provide your name, contact information, and a brief biographical sketch.