The proposed 2024 Medicare Physician Fee Schedule is upon us, which means now's the time to let the U.S. Centers for Medicare & Medicaid Services know what you think of the provisions.
Yes, it's a huge rule (as always), and yes, it's complex (as always). But APTA can help you understand what's on the table, how it might affect your work, and ways to make your voice heard.
There are several ways to get an idea of what's in the proposed rule. We've published a two-part series (part one, part two) that provides highlights; we recorded a podcast that covers the same ground, and we're offering a live webinar on the proposal (along with other hot regulatory and payment topics) on Aug. 24, with a recording available soon after.
There are also options for providing comments: APTA's patient action center offers a templated letter that you can send to CMS — quick and easy. However, if you want to participate in what CMS says will be a more effective approach, consider authoring your own comment letter. APTA offers resources to make it as easy as possible, including step-by-step guidance and an instructional video. And if you want to know why your individual comments are so important, APTA staffer Andrew Amari, JD, lays it all out in this perspective.
So what is it about this year's proposed fee schedule that makes it worth your time? Here are four considerations.
1. This Is One of the Biggest Opportunities for Positive Change We've Seen
Typically, the proposed fee schedule puts providers on the defense, forcing advocacy around potential cuts, increased administrative burden, and other challenges. And while the 2024 proposal does contain significant cuts opposed by APTA (and other provisions that are problematic for the profession and patients), this time around there are multiple opportunities to tell CMS that it's moving in the right direction and help to push issues over the goal line. And when it comes to the policies you oppose, remember: Not commenting is as good as telling CMS you're OK with the proposal.
2. CMS Is Closer Than it's Ever Been to Changing Course on PTA Supervision (and That's a Good Thing)
After years of APTA and other organizations advocating that CMS change supervision requirements for PTAs in private practice settings from direct to general, the agency has finally put out a call for comments on the idea. This is our chance to press for an important change that will improve patient access and relieve administrative burden.
3. PTs and PTAs Could Get Paid for Something They're Probably Already Doing for Free
The proposed rule includes new CPT codes for caregiver training without the patient present. Not only is the proposed change good for PTs and PTAs it represents an important move toward health equity by helping patients with disabilities or other serious conditions ensure that their caregivers are adequately trained to support them.
4. The Quality Payment Program May Expand Further Into Physical Therapy (for Better and Worse)
The proposed rule includes a low back pain cost measure — a definite step in the right direction when it comes to the Merit-based Incentive Payment System, or MIPS, and MIPS Value Pathways. But CMS also wants to push MIPS provisions for promoting interoperability to physical therapy before the profession is ready.