The proposed 2024 Medicare Physician Fee Schedule is open for public comment, and APTA is urging the profession and supporters to make their voices heard by Sept. 11. While you can still speak up through a standard templated letter, an even better strategy is to provide your individual perspectives on the proposal. There are some very important reasons why your take matters more than thousands of identical letters, and APTA offers resources to help you through the process.

But why the call to action? The general answer is, it's always important to comment on proposed rules and regulations. The more specific answer is, the 2024 proposed rule provides some outstanding opportunities to speak up for positive change, at a time when CMS appears to be listening. In a recent APTA podcast on the fee schedule, APTA Director of Health Policy & Payment Kate Gilliard, JD, said the proposal makes 2023 "the most important year for regulatory advocacy that I've ever seen."

You can see for yourself by reviewing the entire proposal. If slogging through a 1,000-plus page document isn't your thing, you can get distilled insights from APTA via our two-part review (part one, part two) the podcast mentioned above, or by way of a recorded webinar.

Or maybe you understand the importance of providing comments, but just need a quick take on possible topics to cover. Here are four big ones. (But remember, these are just the bigger issues — there may be other proposals that mean just as much to you. If so, let CMS know.)

1. Continued cuts are unsustainable.

CMS is proposing yet another cut for 2024 by once again reducing the conversion factor, resulting in an estimated 3.3% decrease. The continued squeeze on therapy providers is ultimately a threat to patient access to needed care. You likely have firsthand experience of the real-world effects on these cuts. Tell CMS.

2. PTA supervision needs to be general regardless of setting.

Private practice settings remain the sole settings in which direct supervision of PTAs is required. This needs to change. The pandemic showed the health care world that virtual supervision — in many ways, a type of general supervision — is not only possible but also effective in private practices. Share your experiences, especially regarding the ways patient care was enhanced through lower administrative burden.

3. Caregiver training codes (with appropriate payment for them) are a good idea.

CMS proposed the adoption of codes that would allow PTs, OTs, speech-language pathologists, and other providers to bill for providing training to caregivers of patients living with a functional deficit — something many PTs and PTAs have been doing for free. Your personal experiences with caregiver training and the differences that training can make in the life of patients are worth sharing.

4. Level the playing field for QPP and MIPS.

Proposals around components of the Quality Payment Program — specifically, those related to the Merit-based Incentive Payment System, or MIPS, and the related MIPS Value Pathways program — are somewhat of a mixed bag. On one hand, the proposal to allow PTs to report the first-ever physical therapy-related cost measure (low back pain) for purposes of MIPS and MVP is a move in the right direction. On the other hand, CMS also wants PTs to begin reporting in the "interoperability" category of MIPS, something that requires more of a runway than the six months provided in the proposed rule. If CMS really wants to speed up the evolution toward outcomes-based care throughout the health care environment, it needs to avoid putting some provider types at a disadvantage.