Comments on CMS' 2026 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies proposed rule (September 2025)

On behalf of the Private Practice Section of the American Physical Therapy Association (APTA Private Practice), we appreciate the opportunity to submit comments in response to the above-referenced proposed regulation (the Proposed Rule). APTA Private Practice represents nearly 4,000 members engaged in physical therapy private practices across the country. These practices are deeply committed to improving patient outcomes, advancing innovation in musculoskeletal care, and ensuring the sustainability of high-value, community-based physical therapy.

We commend CMS for its commitment to transparency and to aligning payment systems with value-based care. However, we are deeply concerned about the proposed Relative Value Unit (RVU) adjustments for physical therapy services. If left uncorrected, these adjustments will threaten the financial viability of private practices, restrict patient access, and undermine Medicare’s broader goals of prevention, cost efficiency, and health promotion. Our comment focuses on nine major areas:

•  I. Making America Healthy Again
• II. Conversion Factor (CF) Update and the State of the Physical Therapy Profession
• III. Relative Value Unit (RVU) Adjustments IV. Eliminate Application of the Multiple Procedure Payment Reduction Policy V. Documentation and Audits
• VI. Replace Medicare’s 8-Minute Rule VII. Expand Plan of Care Signature Exception to Direct Access Patients and Recertification VIII. Remote Therapeutic Monitoring (RTM)
• IX. PTA Supervision X. Telehealth XI. Make Merit-Based Incentive Payment Program (MIPS) Participation Voluntary
• XII. Other Value-Based Care Models and the Ambulatory Specialty Model (ASM) XIII. Other Items

Read the full letter here.