The proposed 2025 Home Health Prospective Payment System rule provides several opportunities for PTs, PTAs, and students to advocate for provisions that will benefit the profession and the patients we serve. APTA is making it easy to do so with two options: our online comment tool and our template comment letter.
Whether you have 30 seconds to add your support to APTA's positions on the rule via the template letter or have a longer individual story to tell about the rule’s impact on your practice and want guidance from our comment tool, check out APTA's Regulatory Action Center to see how you can contribute meaningful feedback to help improve physical therapist services in the home health setting.
What's at stake? In the proposed rule, the Centers for Medicare & Medicaid Services responded directly to advocacy by APTA, the American Occupational Therapy Association, and the American Speech-Language-Hearing Association toward ensuring that therapy provided by home health agencies is appropriate and timely. CMS made its first concrete step toward this by proposing a major addition to the HHA Conditions of Participation, which, if finalized, would create more transparency and accountability in an HHA's ability to accept referrals and initiate services.
More directly to PT practice, the proposed ruling includes two RFIs — requests for information to inform future rulemaking — that are important for the physical therapy community to give feedback on. First, CMS is considering permanently allowing therapists to conduct the initial and comprehensive assessments for HHA orders that require both therapy and skilled nursing; the agency wants to determine whether therapists are equipped to safely and appropriately initiate episodes of care for these "some therapy" orders. Currently, therapists are permitted to do so only when the order is solely for therapy services.
This is a significant opportunity for therapists to weigh in on a regulatory barrier that can prevent them from seeing their patients in a timely manner. If the feedback is positive, expect this change in next year's home health rulemaking.
Second, the agency is exploring stakeholder concerns that HHAs are prioritizing their bottom line over individualized plans of care based on patient need. Therapists have had challenges with the level at which they are allowed by home health agencies to provide care based on their clinical recommendations for the patients' needs. To this end, CMS seeks input on current practices within HHAs as it considers potential action in the future.
These RFIs indicate an uptick in CMS scrutiny of HHAs' business practices and their impact on patient care, and it could be a harbinger of added protections that better enable PTs and PTAs to provide services without burdensome restrictions.
Take advantage of APTA's advocacy tools. Now that you know the why, here is the how. APTA's comment tool walks you through writing a personalized letter that shares your experiences and explains the impact the provisions of the ruling and RFIs would have on your practice. If time is an issue, you also can help advocate for the profession's positions by filling out and submitting our prewritten template letter.
APTA's Regulatory Action Center gives you a summary of the issues and guidance to help you maximize your impact.
Oh, and by the way, the American Society of Association Executives believes so strongly in the tool's potential that it gave APTA a silver award in its national Power of Associations competition.