On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the final 2025 Medicare Fee Schedule rule which includes two major advocacy wins for the PT profession as a result of APTA advocacy. APTA is reviewing the rule in its entirety and will report on additional provisions in the coming days; meanwhile, here’s an overview of selected elements of the fee schedule.

Supervision of Physical Therapist Assistants 

In response to APTA advocacy, the supervision requirement for physical therapist assistants under Medicare Part B will change from the current outdated direct supervision requirement to general supervision. This change finally will align outpatient settings with the general supervision policy in place in all other Medicare settings. What’s more, 49 states already permit general supervision of PTAs under state licensure laws, meaning Medicare’s direct supervision requirement in the outpatient setting was more burdensome than most state licensure requirements. This change will provide more flexibility for the therapy workforce and ensure access to therapy services for millions of Medicare beneficiaries, especially in rural or underserved areas, where beneficiaries are 50% more likely to receive therapy from a PTA. The language in the final rule mirrors the APTA-backed legislation introduced in the 118th Congress, titled the EMPOWER Act, that would require CMS to make this long-advocated for change. With this policy change finalized in the 2025 fee schedule, the legislation is no longer needed.

Therapy Plan of Care Certification Requirement Reform

Thanks to APTA member advocacy, an exemption is being provided to the current burdensome plan of care signature requirement for outpatient therapy services provided under referral from a physician. Under current CMS policy, physical therapists are required to send their plans of care to the referring physician, who has 30 days to sign off on the services that the referring physician ordered in the first place. If the 30-day deadline is approaching and the physician still hasn’t returned the signed plan of care, it has been up to the physical therapist to obtain that signature. Without it, the PT is faced with not being paid by Medicare or stopping patient treatment, which can result in interruptions in care. Under the new exemption, the plan of care certification signature requirement will be deemed satisfied if the physical therapist simply submits the plan of care to the patient’s referring physician within 30 days of the initial evaluation; PTs no longer need the physician’s signature. This change comes after APTA advocacy during the CMS comment period and mirrors the APTA-backed legislation introduced in Congress, titled the REDUCE Act. Again, with CMS’ action in the final rule, the legislation is no longer needed.

Conversion Factor Cut 

The 2025 final rule also finalized a reduction to the fee schedule’s conversion factor. As in previous years, the budget-neutral policy has led to another cut to the conversion factor that impacts all providers paid under the physician fee schedule, including physical therapists. Unless Congress intervenes — which it has done several times in past years — the 2025 conversion factor will be $32.3562, a 2.8% decrease from 2024.

It is now up to Congress to stop the impending 2.8% cut from being implemented in January 2025. In a bipartisan effort to address this, APTA-supported legislation, the Medicare Patient Access & Practice Stabilization Act, was introduced in the U.S. House on Oct. 29. If enacted, it would provide a 4.73% payment boost to the 2025 Medicare Physician Fee Schedule’s conversion factor, for a net increase of 1.9%. Be on the lookout for upcoming grassroots opportunities.

For additional insights, join us on Nov. 14 for a live webinar on the final rule. Please stay tuned for additional update.