CMS Payment Reform: Your Voice Is Needed by September 14 kapak görseli

CMS Payment Reform: Your Voice Is Needed by September 14

CMS Payment Reform: Your Voice Is Needed by September 14

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What happens when the people delivering healthcare actually participate in deciding how that care is valued?Right now, we have an opportunity to do exactly that.CMS is accepting public comments on the CY 2027 Medicare Physician Fee Schedule proposed rule, and the deadline is September 14, 2026.If you are a U.S.-based occupational therapist, physical therapist, speech-language pathologist, or another rehabilitation or allied health provider, this is a moment to pay attention and participate.Read the CMS CY 2027 Medicare Physician Fee Schedule proposed ruleSubmit a public comment through Regulations.govSearch for CMS-1848-P when submitting your comment.Why this mattersPayment policy is about much more than reimbursement rates. It influences what healthcare systems prioritize, how services are structured, what work is considered valuable, and what kinds of care are realistically available to patients.For rehabilitation providers, there can be a significant gap between the work that actually produces meaningful outcomes and what can be easily represented through a billing code.Think about what goes into a complex rehabilitation encounter. There is the assessment itself, but also the clinical reasoning behind it. There is communication with caregivers and other providers, environmental analysis, education, risk management, adapting interventions to the individual, coordinating care, and making decisions based on information that may not be captured by a single diagnosis or procedure code.For many of us, these are not extras added onto the work.They are the work.That makes this comment period important.Rather than simply saying that reimbursement is too low, we have an opportunity to explain what current payment structures fail to capture and what that means for patients, providers, and the healthcare system.What is changing?The CY 2027 proposed rule includes changes and requests for input related to how Medicare services are coded and valued, including the Practice Expense methodology and aspects of care management and remote monitoring.These are technical policy issues, but the questions underneath them are surprisingly practical:What does it actually take to provide good care?What resources are required?What kinds of clinical work happen outside the most visible portion of an encounter?How should payment systems recognize complexity, coordination, clinical reasoning, and the resources required to manage patients over time?These are questions rehabilitation providers have direct experience answering.OT Potential’s Sarah Lyon and colleagues have been particularly active in bringing OT and PT perspectives into this conversation. Their proposed recommendations include better differentiation in reimbursement for evaluation complexity and consideration of non-time-based therapist management codes to recognize some of the ongoing clinical work that occurs throughout an episode of care.You do not have to agree with every recommendation to see the value in participating.In fact, this is one of the things I appreciate about the public comment process. It gives us an opportunity to respond to what is actually being proposed, identify what we think is missing, describe unintended consequences, and offer alternatives based on what we see in practice.Start with Sarah Lyon’s episodeIf you want some context before diving into the policy language, I recommend starting with Sarah Lyon’s recent OT Potential episode on this issue.Listen to the OT Potential episode on YouTubeThe episode provides a useful overview of the current opportunity and the work underway to bring rehabilitation perspectives into the Medicare payment conversation.OT Potential has also created a 2027 CMS Comment Template for OT and PT care, which makes the process considerably easier if you are staring at Regulations.gov wondering where to begin.Access the OT Potential CMS Comment TemplateThe template provides language you can adapt, along with references and guidance for submitting your comment. I would encourage you to personalize it rather than simply submitting the exact same language as everyone else.Your own experience is what makes the comment valuable.What can you contribute?Start with the part of the system you know.Maybe you work with patients whose needs are more complex than the evaluation code adequately communicates. Maybe much of your clinical expertise involves adapting care to cognition, environment, caregiver capacity, health literacy, routines, transportation, safety, or other contextual factors.Maybe you spend substantial time coordinating with other disciplines and caregivers. Maybe your work involves preventing a problem rather than treating the consequences after it happens.Maybe you have watched a patient avoid an emergency department visit because someone identified a risk early. Maybe you have helped a family safely manage a transition home. Maybe your interdisciplinary team caught something that would have otherwise ...
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