Regulatory Action Center

APTA comments are made on behalf of our membership and profession on federal regulations and draft guidance based on the Public Policy Priorities of the American Physical Therapy Association.

We encourage members and nonmembers to provide feedback: Your perspectives are critical to policy development. APTA has developed tools to help you easily draft a personalized comment letter using APTA's comment letter guide. Alternatively, you can use one of our prewritten template letters to submit comments.

Current Opportunities

CMS CY 2025 Home Health Proposed Rule

The U.S. Centers for Medicare and Medicaid Services released the calendar year 2025 Home Health proposed rule, which estimates a -1.7% payment update, approximately a $280 million decrease in payments to home health agencies relative to 2024. However, there are several critical opportunities that physical therapists may wish to submit comments on. Most notably, CMS is seeking feedback through a "Request for Information" (RFI) asking whether therapists should permanently be permitted to conduct the initial and comprehensive assessments where an order has both nursing and therapy; this is being considered for future rulemaking in response to APTA advocacy. Currently, therapists are permitted to do so only when the order is solely for therapy services. Second, the agency is exploring stakeholder concerns that HHAs are prioritizing their bottom line over individualized plans of care based on patient need through another RFI, asking whether patients are receiving individualized plans of care based on clinical need. Finally, CMS is proposing new Conditions of Participation for home health agencies that would require them to develop, implement, and annually review an acceptance-to-service policy and apply it consistently to each patient referred to home health care. Each HHA would be required to publicly provide information regarding case load and mix, anticipated needs of referred patients, current staffing levels, and staff competencies. The goal, CMS notes, is to improve the climbing rate of referral rejections. Comments are due by August 26, 2024.

Relevant Documents: Review Proposed Rule | Review Fact Sheet

Take Action: APTA Comment Tool (Submit Individualized Feedback on the 2025 Home Health Proposed Rule) | Template Comment Submission

Deadline for Comments: Aug. 26, 2024 at 5:00 p.m. ET.

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