APTA Private Practice

The American Physical Therapy Association Private Practice Section (APTA Private Practice) has formally submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Draft 2026 Medicare Physician Fee Schedule (MPFS). The letter underscores the vital role of physical therapy in America’s health system, while raising serious concerns about policies that could weaken access to care, undervalue services, and threaten the financial sustainability of private practices.

In its comments, we acknowledge CMS’s proposed 3.3% increase to the conversion factor for non-qualifying Alternative Payment Model participants. However, we also stress that this increase is “effectively nullified” by reductions in Relative Value Units (RVUs) for Physical Medicine & Rehabilitation codes. These reductions would disproportionately affect physical therapy practices. While CMS positions the MPFS as a pathway to transparency and value-based care, we argue that the draft rule undermines those very principles. By misapplying efficiency adjustments and redistributing practice expenses, the agency risks creating payment distortions that harm both providers and patients.

Our Main Points

  • RVU Adjustments: We strongly oppose unexplained and inconsistent RVU reductions, warning they will reduce reimbursement for common therapy services while failing to reflect the clinical value of physical therapy.
  • Practice Expense Redistribution: The draft rule shifts resources away from physical therapy, unfairly penalizing providers who already operate with lower overhead than physician specialties.
  • Efficiency Adjustment: CMS’s use of efficiency factors fails to account for the high value and cost-effectiveness of physical therapy. We argue that efficiency should be rewarded, not punished.
  • Telehealth Flexibilities: We urge CMS to permanently extend telehealth coverage for physical therapy, highlighting the strong outcomes and access improvements demonstrated during the COVID-19 public health emergency.
  • PTA Supervision Requirements: We reiterate that burdensome direct supervision rules for physical therapist assistants (PTAs) in private practice settings reduce efficiency without improving quality.
  • Documentation and Audits: Concerns are raised about growing administrative burdens, particularly around documentation requirements and audit processes that add cost without improving patient outcomes.

System-Level Impacts

The comment letter goes beyond provider concerns to emphasize broader system impacts. We warn that continued devaluation of physical therapy will discourage participation in Medicare, limit patient access to non-pharmacological interventions, and ultimately drive up costs as beneficiaries turn to higher-cost medical and surgical options.

The letter also connects these concerns to CMS’s stated commitment to value-based care. Physical therapy, we note, is a proven, evidence-based intervention for preventing and managing chronic disease. Undervaluing therapy services contradicts the agency’s goals of promoting prevention, lowering costs, and improving quality of life for beneficiaries.

The filing concludes with a call for CMS to revise its proposals to reflect the true value of physical therapy. We urge members and stakeholders to join in advocacy efforts by submitting comments, contacting lawmakers, and educating policymakers about the essential role private practice physical therapists play in the healthcare system.

Now that the comment period has closed, we will continue working with CMS, Congress, and allied health organizations to ensure fair reimbursement and sustainable policies. The outcome of this rule will shape how physical therapists deliver care to millions of Medicare beneficiaries in the years to come.