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The U.S. Centers for Medicare & Medicaid Services has closed the public comment period on its proposed 2022 Medicare physician fee schedule — which begs a question:

What happens next?

For APTA, its members, and supporters of the profession, the answer is "a lot."

The end of the comment period marks the beginning of a push to focus on Congress. The pressure is on to make the case that lawmakers should be prepared to address CMS plans to enact a severe payment cut, launch a PTA payment differential, and ignore calls for changes that would make PTs eligible to provide reimbursable services via telehealth beyond the current public health emergency.

The pivot is the second element in a two-part strategy being pursued by APTA: Press CMS to alter course, then use the grassroots engagement with CMS to help strengthen the case for change at the congressional level.

And now that the dust has settled on the comment period to CMS, it's clear that APTA will be able to back up its advocacy with numbers: CMS received more than 10,000 letters through APTA advocacy channels, comprising more than one-third of the total comments it received on a proposal that included payment cuts to some three dozen professions.

According to Justin Elliott, APTA vice president of government affairs, lawmakers now have tangible evidence that constituents want CMS to change course on the proposed 2022 fee schedule rule, providing justification for Congress to intervene if CMS doesn't address the issues.

"The wave of comments CMS received from the physical therapy community makes it clear that the provisions of this proposed rule will have a real-world impact on people who live in their states and districts," Elliott said. "Advocacy is always more powerful when it's clear that grassroots support is strong."

Making the Pivot

APTA wasted no time in turning its grassroots focus to Congress. CMS closed its fee schedule comment period on Sept. 13; on Sept. 14, APTA held an advocacy day in Washington, D.C., that drew more than 450 PTs, PTAs, students, and supporters, generating nearly 300 meetings with members of Congress and staffers.

While timing for a major grassroots push like the one aimed at CMS is being worked out, there are still opportunities to make your voice heard: APTA's Patient Action Center provides an easy way to send comments to lawmakers on both the cuts and another piece of legislation that could impact the fee schedule: a bill that would add PTs and PTAs to the list of providers allowed services via telehealth under Medicare.

The key moving forward will be a physical therapy community that's tuned in to the issue and ready to act quickly. That level of readiness is made easier by way of the APTA Advocacy App, a free offering that keeps users in the loop and makes connections with lawmakers easy (search for "APTA Advocacy" in Apple or Google app stores).

Laura Keivel, APTA's grassroots affairs specialist, says that if engagement with CMS is any indication, grassroots advocacy to Congress could be impressive.

"Again this year, our members and supporters did an amazing job of making their voices heard at CMS," Keivel said. "I believe that when it's time to really put the pressure on Congress, we'll see that same level of passion, and more."


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