Make Your Voice Heard! Comment about Therapy Cuts and Telehealth to CMS

By Monica Wright posted 09-08-2020 14:15


On August 3, 2020, the Centers for Medicare & Medicaid Services (CMS) released the proposed FY 2021 Medicare Physician Fee Schedule (MPFS) Rule and Fact Sheet. Despite previous collaborative advocacy efforts, the proposed rule contains a 9% cut to reimbursement for therapy services to offset the increases to the value of office visit evaluation and management (E&M) codes that primarily benefit primary care physicians. While AOTA understands CMS’ desire to increase payment to primary physicians, therapy practitioners cannot withstand the cuts required to keep the budget increases neutral. Changes must be made to protect therapy services. 

The MPFS also addresses the continuation of telehealth after the public health emergency (PHE) ends. CMS states that it may be confusing to add the therapy codes permanently because, after the PHE ends, therapists will no longer have the statutory authority to bill telehealth services to the Medicare program. Unless legislation is passed to allow therapy practitioners to perform telehealth on a permanent basis, after the PHE ends therapy codes would only be billable by telehealth-eligible providers, such as physicians. CMS is seeking comment as to whether it makes sense to add the services for physicians to be able to perform therapy codes, and is also seeking feedback and data regarding how effectively therapy services can be performed via telehealth. AOTA continues to advocate for legislation to allow therapy practitioners to bill telehealth services on a permanent basis. In the meantime, CMS needs to extend its waivers beyond the PHE to ensure continued access to therapy services for all Medicare beneficiaries.

Make your voice heard—the time to act is now.

The proposed rule is open for public comments, and every comment letter CMS receives makes a difference. To simplify the process for practitioners, AOTA has created a template letter to respond to the proposed rule by telling CMS to eliminate the payment cuts and allow occupational therapy practitioners to continue to perform telehealth. Comments are due by October 5, and can be submitted at You can access the proposed rule regulation by accessing the Rule document and then clicking the “Comment Now!” button on the top right side of the page and following the directions. Download the four page template letter below.




10-09-2020 09:26

The CMS proposed fee schedule rule window to comment has closed, however it is not too late to reach out to Congress.

The Legislative Action Center has tips and tools for the best ways to reach out to your representatives.

10-08-2020 18:26

Monica, is it too late to send a letter to our senator, I noticed the deadline was 10/5.

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