If a rule from the US Centers for Medicare and Medicaid Services (CMS) is adopted as proposed, physical therapists (PTs) and physical therapist assistants (PTAs) who work in skilled nursing facilities (SNFs) could find those facilities facing some major changes in payment. Those changes could include a new case-mix methodology system and altered therapy reporting requirements, according to CMS.

The rule won't be finalized until later this year. In the meantime, CMS is asking for public comments on its proposal. APTA has made it easy for you to participate.

APTA offers a template letter for PTs and PTAs who want to comment on the proposed 2019 skilled nursing facility prospective payment system (SNF PPS) and the plans for implementation of the Patient-Driven Payment Model (PDPM) to replace the Resource Utilization Groups Version IV (RUG-IV). Among other comments, the letter encourages CMS to take a careful look at how proposed coding requirements associated with the PDPM would "pose significant administrative, financial, and compliance burdens on SNFs."

Posted as a Microsoft Word file, the letter was created with the technical formatting that CMS is accustomed to, but it also includes areas that can be personalized with details and examples from the individual PT's or PTA's practice. Those personal touches can help to underscore the messages that the letter's shared elements deliver to CMS with a unified voice.

APTA outlined the basics of the proposed rule in an APTA fact sheet and will submit its own comments to CMS by the June 26 deadline. CMS has also issued a fact sheet on the proposed rule.