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Use templated letters to take action on payment and regulatory issues impacting your practice.

APTA comments are made on behalf of our membership and profession on federal regulations and draft guidance based on the Public Policy Priorities of the American Physical Therapy Association.

We encourage members and nonmembers to provide feedback: your perspectives are critical to policy development.

Hot Topics in Regulatory Advocacy

Issues in which APTA is currently reviewing and submitting are posted here with templated letters and guidance to make taking action easy.

Open Comment Opportunities

FY2022 Inpatient Rehabilitation Facility Proposed Rule. The proposed rule provides a 2.2% increase ($160 million) in payment, COVID-19-related changes, and efforts to promote health equity. As it did last year, the U.S. Centers for Medicare & Medicaid Services is taking a light touch to changes for inpatient rehabilitation facilities for the 2022 fiscal year. The proposed rule includes a call for comments on promoting health equity, a request for feedback on plans to strengthen interoperability, and a COVID-19 vaccination reporting requirement, among other things.

The final rule would go into effect on Oct. 1, 2021. APTA’s review of the proposed rule provides more details.

APTA will submit comments, and we encourage individuals to also comment using our standard template letter.

Review the IRF Proposed Rule (proposed rule)

Fact Sheet

Deadline for comments: June 7, 2021.

FY2022 Skilled Nursing Facility Proposed Rule. While the proposed rule provides a $444 million increase in payment, CMS is seeking comment on how to correct for a 5% ($1.7 billion) increase in payment in 2020 due to implementation of PDPM, despite a decrease in individual therapy minutes. The proposed rule also includes a call for comments on promoting health equity, a request for feedback on plans to strengthen interoperability, a possible exemption of customized prosthetic devices from consolidated billing, an expanded SNF value-based purchasing program, and a pass on readmission measures in light of the COVID-19 pandemic, among other things.

The final rule would go into effect on Oct. 1, 2021. APTA’s review of the proposed rule provides more details.

APTA will submit comments, and we encourage individuals to also comment using a unique template letter, which will be available soon.

Review the SNF Proposed Rule (proposed rule)

Fact Sheet

Deadline for comments: June 7, 2021.

HHS Releases HIPAA Proposed Rule: In what would be some of the most significant changes to the Health Insurance Portability and Accountability Act since it was adopted in 1996, the U.S. Department of Health and Human Services has proposed a range of modifications that, among other changes, would make it easier for patients to view their own health records or share them with other providers. On the provider side, the proposed rule would make it easier to share patient data — and more of it — among providers and health plans. APTA's review of the proposed rule provides more details.

APTA will submit comments, and we encourage individuals to also comment using standard template letter.

Review the Modifications to the HIPAA Privacy Rule (proposed rule)

Review: Press Release and Fact Sheet

Deadline for comments: May 6, 2021.

VA Criteria for Developing Recommendations for the Future of Veterans' Health Care: The Department of Veterans Affairs seeks feedback on a draft decision it has published on criteria that will be used to develop recommendations for ensuring high-quality, readily accessible, cost-effective care throughout VA. The criteria are based on factors outlined in the VA Mission Act of 2018 and include these categories: veterans’ need for care and services, accessibility of care for veterans, impact on mission, providing the highest-quality whole health care, effective use of resources for veteran care, and ensuring a safe environment of care.

APTA will submit comments, and we encourage individuals to also comment using standard template letter.

Review the VA's notice and request for comment.

Press Release

Deadline for comments: May 1, 2021.

General Template Letter

If a specific template letter above does not apply, use our standard template letter to submit comments.

Simply insert your individual information where indicated.

Your comments represent only you and your situation; they should not imply representation of the association.

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 advocacy@apta.org and provide your name, contact information, and a brief biographical sketch.