I appreciate the opportunity to provide comments to the Centers for Medicare & Medicaid Services in response to the 2021 Physician Fee Schedule (PFS) proposed rule.

I strongly oppose CMS’ significant payment reductions for occupational therapy (OT), physical therapy (PT), speech therapy (SLP) services. I understand that the proposed 9% cut to therapy is the result of increases in payment to primary care physicians and the statute regarding budget neutrality for CMS. However, it is irresponsible to proceed under the current proposed PFS, in which these increases are made at the expense of other essential services. Action must be taken to ensure this does not happen.

Implementing these cuts at all, but especially in the wake of the effects of the Covid-19 pandemic, is ill-advised and will have dire consequences. OT/PT/SLP practitioners provide essential services to maximize and improve the quality of life of Medicare/Medicaid beneficiaries. As a result of Covid-19, individuals are experiencing greater amounts of cognitive impairment, neuromuscular damage, fatigue, and psycho-social challenges – all of which interfere with one’s ability to participate safely in necessary and meaningful day-to-day activities. These individuals require OT/PT/SLP services. The proposed 9% cut will result in insolvency, forcing practices which provide these essential services to shutter in both metropolitan and rural communities. The ripple effect will include job loss, increased hospitalizations & spending, and the loss of access to quality care by Medicare/Medicaid beneficiaries. CMS must immediately halt implementation of the 9% reduction to Occupational Therapy, Physical Therapy, and Speech Therapy services.

Additionally, it is well documented that many needs can be effectively met via the use of technology and that patients can have improved access to skilled care by leveraging these resources. I therefore strongly recommend these codes be made billable by OT/PT/SLP telehealth providers permanently beyond our Public Health Emergency: 97110, 97112, 97116, 97150, 97165, 97166, 97167, 97168, 97530, 97535, 97542, 97750, 97755, 97760, 97761, 96110, 96112, 96113, and 96127. This change will ensure that Medicare/Medicaid beneficiaries have access to valuable services not limited by geographic proximity or medical infirmity. Therapists must be able to provide and bill these codes on a permanent basis.

In all times and especially now, it is crucial that Medicare/Medicaid beneficiaries receive uninterrupted, medically necessary services needed for their health and well-being. Thank you for your consideration on this urgent matter.

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