Comment Letter to Advocate Against the Proposed Decrease to PT/OT Medicare Reimbursement in 2026

If you DO NOT comment on the 2026 Physician Fee Schedule proposed rule, you are basically endorsing the ongoing reductions to occupational and physical therapy reimbursement. 

Luckily, we are making advocacy super simple for you. 

With the content provided here, you can make your voice heard with just 5 minutes of your time. 

Your 1-minute crash course on therapy reimbursement 

Here is the calculation Medicare uses for occupational therapy/physical therapy reimbursement, which is published as part of the larger physician fee schedule. 

In this year’s proposed rule, non-facility PT and OT are proposed to receive a -1% reduction to our practice expense RVU, which—along with no changes to our work and professional liability insurance RVUs—leads to an estimated combined impact of -1%. 

This is alarming, because when adjusted for inflation, our reimbursement is already down around 40% since 2002 on our key CPT codes. 

What makes this even more alarming is that RVUs are being re-weighted this year to shift value from non-timed codes to time-based codes, which should be favorable for us since we primarily bill time-based codes. So, while our fellow time-based providers (like clinical social workers, PAs, and nurse practitioners) are receiving significant increases of +4% to +6%, we have been left out. 

Comparing Impact on Non-facility Charges for Time-based Providers on Table 92 of the 2026 Proposed Physician Fee Schedule.

	Impact of Work RVU Changes	Impact of Practice Expense RVU Changes	Impact of Malpractice RVU Changes	Combined Impact
Clinical Social Worker	4%	3%	-1%	▲ 6%
Nurse Practitioner	0%	5%	0%	▲ 5%
Physician Assistant	0%	4%	0%	▲ 4%
Physical/Occupational Therapy	0%	-1%	0%	▼ -1%

This shift toward time-based codes is also part of a multi-year rollout. If we do not establish ourselves as critical frontline time-based providers this year, we will likely miss out on increases over the next several years. The time for advocacy is now. 

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5 steps for submitting your comment letter

Here’s what you need to do. 

1. Draft your comment by using the template below. (Copy and paste the template directly. Or, edit it to make the letter your own, but be sure you include the proper formatting as demonstrated below.)
2. Go to the Federal Register page before September 12, 2025.
3. Use the green submit button to share your comment. (You can either attach a PDF or paste your letter into the text box provided.) 
4. On “What is Your Comment About?”, click Occupational Therapist or Physical Therapist.
5. Submit and celebrate! 🎉

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OT Potential’s Working Draft of a Comment Letter to use as a template 

We are sharing the working draft of our comment letter for two reasons. 

1.) We want OTs and PTs to start commenting today! An imperfect comment is better than no comment. And, we hope this draft gives you a starting point. 

2.) We welcome feedback on our arguments. Let us know in the comments if you have any suggestions, and we will continue to tweak this letter based on feedback. 

We will also watch for comment letters from the AOTA and ASHA and share them here as they become available.

You can find APTA’s Comment Letter on this page. It is titled: Urge CMS to Recognize the Value of Physical Therapy in the 2026 Fee Scehdule. 

If you use our letter below as your template, be sure to change the parts highlighted in yellow. 

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Copy & Paste Version!

This is short enough to drop in the text box! Just go to this page and drop it in! (Don’t forget to change the parts highlighted in yellow.)

September _, 2025

Dr. Mehmet Oz
Administrator, Centers for Medicare & Medicaid Services

Stephanie Carlton
Deputy Administrator and Chief of Staff, Centers for Medicare & Medicaid Services

John Brooks
Deputy Administrator and Chief Policy and Regulatory Officer

Centers for Medicare & Medicaid Services (CMS)
Department of Health and Human Services (HHS)
Attention: CMS–1832
P.O. Box 8016
Baltimore, MD 21244-8016

Re: Calendar Year 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program

Dear Administrator Dr. Oz, Deputy Administrator Carlton, and Deputy Administrator Brooks:

Thank you for CMS’s focus on lowering chronic disease rates and rethinking healthcare value. However, I am deeply concerned about the proposed -1% reduction in RVUs for non-facility-based occupational therapy (OT) and physical therapy (PT), especially as other time-based providers receive increases (+4–6%). This cut continues a long trend of reduced reimbursement for OT/PT, jeopardizing access to essential, cost-effective care.

OT/PT services are time-based, evidence-backed, and critical to addressing chronic conditions. Yet CMS’s own Table 92 shows we are the only frontline, time-based providers facing cuts:

• Clinical Social Work: +6%
• NPs: +5%
• PAs: +4%
• General/Family Practice: +6%
• OT/PT: -1%

This comes after a 3% cut in 2024 and flat rates in 2025. Adjusted for inflation, reimbursement for key rehab CPT codes has dropped ~40% since 2002. This decline harms workforce sustainability and patient access. OT/PT salaries lag behind similarly trained professions—despite OT moving to entry-level master’s degrees and PT to entry-level doctorates. Applications to OT school are down 45% since 2016.

Importantly, OT/PT represents a tiny fraction of Medicare spend—outpatient OT totaled only $1.6B of Medicare’s $8.4T spend in 2021 (~0.02%)—but we deliver outsized value. Our services are proven to improve outcomes and reduce costs for stroke, dementia, low back pain, osteoarthritis, and more. Many clinical guidelines now recommend OT/PT as first-line care.

Instead of reducing access, we urge CMS to reclassify OT/PT as part of the primary care team, not specialty care. Our work directly supports CMS’s strategic aims: shifting to preventive, non-pharmacologic, cost-effective care; reducing reliance on drugs and surgery; and promoting behavior change for improved health.

We respectfully request that CMS reweight the Work and Practice Expense RVUs for non-facility-based OT and PT, aligning us with fellow time-based providers. A 3-year phased increase to match +4–6% levels would better reflect our value, support workforce stability, and improve access for millions of Americans.

Thank you for your attention to this critical issue.

Sincerely,
[Your Name, Title]

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Full Version

Here is the full argument. If you want to submit a longer version like this, you will need to upload it as a PDF here.

Submitted via regulations.gov

Dr. Mehmet Oz
Administrator
Centers for Medicare & Medicaid Services, Department of Health and Human Services
Attention: CMS-1832-P
P.O. Box 8016
Baltimore, MD 21244-8016

September .., 2025

Re: Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program

Dear Administrator Oz,

We applaud the emphasis CMS places on “understanding and drastically lowering chronic disease rates, including thinking on nutrition, physical activity, healthy lifestyles, over-reliance on medication and treatments, the effects of new technological habits, environmental impacts, and food and drug quality and safety.”

Unfortunately, the estimated decrease to physical therapy (PT) and occupational therapy (OT) reimbursements undercuts two key professions that are the most poised to mobilize on this effort. Within this proposed rule, we were alarmed to see how the occupational therapy and physical therapy professions would fare based on the RVU re-weighting calculations. CMS proposes that non-facility-based OTs and PTs receive a -1% change to their Practice Expense RVU weight and no increase to our Work RVU for a combined impact of -1%. 

For the purposes of our comments, we will focus solely on the changes to RVUs for non-facility-based providers, looking at how these changes compare to those for other time-based providers—and how these potential cuts could undermine the vision set forth to make America healthy by decreasing patient access to the evidence-based, preventative, low-cost, high-value care that is delivered by OTs and PTs. 

OT/PT compared to other front-line time-based providers

We understand the reasoning behind changing the inputs used to calculate updates to Work RVUs and Practice Expense RVUs. We also support shifting value from certain non-time-based codes to time-based codes. As you know, time-based services—including behavioral health services and many services provided by primary care physicians and advanced practice providers—are crucial to developing patient-provider alliances that lead to improved longitudinal outcomes.

We applaud rate increases for our fellow frontline time-based providers, in both their Work RVUs and Practice Expense RVUs. But, we are deeply concerned about PT/OT being left out of these increases—and the overall impact of continually decreasing therapy reimbursement on access to conservative, preventative care in America. 

As stated in Table 92: CY 2026 Estimated Impact on Total Allowed Charges by speciality, the combined impact of non-facility RVU changes for members of the primary care team are as follows: 

• Clinical Social Work: +%6
• Nurse Practitioners: +5% 
• Physician Assistant: +4%
• General Practice: +6%
• Family Practice: +6%
• Occupational/Physical Therapy: -1%

Collapsing OT/PT reimbursements, salaries, and workforce numbers amid increasing costs and worsening outcomes

Unfortunately, the proposed 1% decrease to OT and PT RVUs in 2026 comes after a 0% increase in 2025 and a 3% decrease in 2024. In fact, when adjusted for inflation, reimbursement rates for key rehabilitation CPT codes are down around 40% since 2002. (See Figure 1 below.) 

This has set off a cascade of negative impacts that severely limits our workforce as well as access to our services. Our salaries have not kept pace with fellow entry-level master’s degree professions. The median wage for occupational therapists is $98,340. Physical therapy requires an entry-level doctorate, yet the median annual wage for physical therapists is only $101,020. Compare this to physician assistants and nurse practitioners—professions that require entry-level master’s degrees and have annual median wages of $129,210 and $133,260, respectively. Is it any wonder why applications to OT school are down 45% since 2016? (See Figure 2.) 

The decreasing OT/PT rates might be palatable if our services were simply no longer needed—or if health outcomes and spending were improving. 

But, since 2002 (the beginning of the multi-year period during which PTs and OTs have received consistent reimbursement reductions), national healthcare expenditures have tripled. Meanwhile, the prevalence of chronic disease has steadily increased. 

Over this same period, the quality and complexity of our largely time-based services have increased dramatically. This is evidenced by our profession’s transition from entry-level bachelor’s degrees to entry-level master’s and doctoral degrees. The work of knowledge translation during every patient interaction has also become infinitely more complex, as we have an exponentially growing body of evidence from which to draw.

OT/PT represents a small fraction of of overall healthcare costs, but our services are proven to improve outcomes and reduce spend

Outpatient PT and OT services make up a small fraction of healthcare spend. (In 2021, Medicare payments on outpatient occupational therapy services totaled $1,614 million, whereas total Medicare spending that year came to $8,394 billion.)  Using those numbers, occupational therapy outpatient services make up just 0.019% of total Medicare spend. This proportion is low for several reasons, two of the most important factors being:

1. Low and dropping reimbursement rates that don’t reflect the clinical and economic value of the OT and PT professions.
2. Lack of access to patients when and where they need OT and PT services (e.g., as part of advanced primary care teams).

Low reimbursement rates, combined with limited access for patients when and where they need OT and PT expertise, has kept total spend very low—and the OT and PT professions underleveraged in the call to increase preventative care access.

And yet, despite being continually underleveraged, OT and PT have clearly demonstrated their value. 

Occupational therapy and physical therapy have a strong evidence base demonstrating cost-effectiveness. (See Table 2.) Studies show our economic benefit for conditions such as: low back pain, cognitive decline, osteoarthritis, musculoskeletal disorders, and stroke—conditions that, without early intervention, often progress to stages requiring expensive specialty care. 

Because of the high value of our care, occupational therapy and physical therapy earned their place in numerous treatment guidelines for acute and chronic conditions. See Table 1 for examples of the numerous high-cost conditions for which OT/PT is consistently recommended, including, but not limited to: low back pain, dementia, osteoarthritis, breast cancer, stroke, and falls. 

With this proven value, occupational and physical therapists can help lower overall healthcare spending for chronic conditions by promoting patient independence, intervening early to prevent expensive downstream complications, and facilitating smoother transitions between care settings. Limiting access to OT and PT will only continue to drive up healthcare spending. 

Envisioning future value creation with OT/PT

All in all, the OT and PT professions are synonymous with the low-cost, high-value care that is desperately needed to better understand, and drastically lower, chronic disease rates. 

We envision a future where OTs and PTs work alongside their fellow primary care team members to deliver high-value, essential first-line services to improve internal, physical, and mental health at the individual, community, and population level—actively preventing downstream reliance on high-cost specialty care, surgical intervention, and medications.

Occupational therapy and physical therapy can play a distinct and needed role on primary care teams, in which we leverage robust evidence to help clients change their habits to change their health. We often undertake the difficult, but high-impact work of behavior change related to: daily movement, sleep, meals, social connection and mental health. 

Instead of decreasing access to our preventative care, which the proposed cut would likely do, we support a future where early access is expanded to allow us to focus on secondary prevention. (See Figure 3 for an explanation of OT’s role at all levels of prevention.)

Our plea to re-weight OT/PT RVUs

To best leverage the approximately 440,000 PT professionals and 230,000 OT professionals across the country, we urge you to make a change to the proposed value of OT and PT RVUs at this critical time. Send the signal that these professions have been misclassified as specialty care providers when they should be considered primary care team members—and that policies constraining patient access to OT and PT must be amended. 

We urge you to re-weight and re-distribute funding toward OT and PT before finalizing this rule —accomplishing this over a 3-year rollout. We ask for a re-weighting to the non-facility OT/PT Work and Practice Expense RVUs, to align us more fully with our fellow front-line time-based providers, who are seeing a 4-6% increase in their combined impact on total allowed charges. This reweighting is critical so we can carry out the necessary work of providing upstream, conservative, and evidence-based healthcare.

Through this re-weighting, you will preserve access to low-cost, conservative care for millions of Americans—giving them safer, more economical alternatives to medication and high-cost specialty care. 

Conclusion

We believe OT and PT are central components of the new era of healthcare you are ushering in. 

Combined with the strategy for new avenues toward value-based payment programs, new ways to measure prevention outcomes, and personal empowerment with health data access, our professions have the power to fundamentally change the health of Americans through a new era that supercharges our proven high-value approach with innovation.  

We appreciate your consideration of these current issues. And, we would like to offer any assistance in drafting next year’s rule. Please contact me if you have questions. 

Sincerely,

/s/

Sarah A Lyon
CEO
OT Potential

Supporting Information

About OT Potential 

OT Potential provides continuing education and clinical decision support for occupational therapy professionals. Headquartered in rural Nebraska, we combine pragmatism and innovation to help bring new evidence and best practices to the point of care. 

Table 1: Evidence-based treatment recommendations that support OT/PT role high-cost medical conditions

In this table you’ll find estimated health care spending for several of the 50 most expensive health conditions in 2019 via Tracking US Health Care Spending by Health Condition and County (2025) JAMA. 

We also include specific recommendations for the role of OT/PT in treatment for these conditions. 

Condition	Total 2019 Spending, USD Billions*	% Covered by Medicare*	Treatment Recommendations that include OT and/or PT
Low back pain	52.89	36.8	Current treatment guidelines, including those from the American College of Physicians, strongly recommend nonpharmacologic interventions as first-line therapy for both acute and chronic low back pain and support the inclusion of occupational therapy and physical therapy as part of a multidisciplinary, biopsychosocial approach, particularly for patients with work-related issues or persistent pain and disability.
Alzheimer disease and other dementias	49.09	38.6	AOTA guidelines and supporting systematic reviews and randomized controlled trials recommend occupational therapy as a core nonpharmacologic intervention for Alzheimer’s disease and other dementias. Strong evidence demonstrates improvements in activities of daily living, behavioral and psychological symptoms, and quality of life for both patients and caregivers.
Osteoarthritis	47.55	43.0	Occupational and physical therapists are defined as essential services in the management of osteoarthritis according to 2019 American College of Rheumatology/Arthritis Foundation Guideline for the Management of Osteoarthritis of the Hand, Hip, and Knee
Breast cancer	44.59	27.3	Occupational and physical therapy are explicitly highlighted as first-line providers for the management of lymphedema in the American Cancer Society/­American Society of Clinical Oncology Breast Cancer Survivorship Care Guideline. Systematic reviews and meta-analyses demonstrate that occupational therapy interventions improve quality of life, physical health, social health, cognitive function, fatigue, and role function in breast cancer patients.
Stroke	43.77	44.0	Current U.S. practice guidelines from the American Heart Association/American Stroke Association (AHA/ASA) and the U.S. Department of Veterans Affairs and Department of Defense guidelines (VA/DoD) recommend both occupational and physical therapy as core components of stroke rehabilitation to maximize functional recovery and independence.
Falls	43.67	45.4	Guideline recommendations from the US Preventive Services Task Force, the American Geriatrics Society/British Geriatrics Society, the CDC STEADI initiative, and the American Physical Therapy Association all consistently support the integration of PT and OT into fall prevention strategies for older adults.
Depressive disorders	41.03	15.0	Occupational therapy is a mandatory part of Medicare’s partial hospitalization programs, and is generally considered a crucial part of the treatment team in psychiatric hospitals. Systematic reviews and meta-analyses highlight the role of occupational therapy in preventive mental health care in schools and communities, promoting wellness and early detection of behavioral health challenges.
Treatment of hypertension	35.57	39.9	Current hypertension treatment guidelines from the American College of Cardiology and American Heart Association (ACC/AHA) and the American Diabetes Association (ADA) both include lifestyle interventions as foundational therapy for elevated blood pressure and hypertension. Current literature provides robust evidence for the effectiveness of OT interventions focused on medication adherence and lifestyle modification, particularly when interventions are individualized and integrated into chronic disease management.
Chronic obstructive pulmonary disease	29.1	55.0	Multiple chronic obstructive pulmonary disease (COPD) treatment guidelines, including those from The American Thoracic Society and Global Initiative for Chronic Obstructive Lung Disease (GOLD), explicitly mention physical therapy as a core component of pulmonary rehabilitation. Two practice guidelines endorse occupational therapy in pulmonary rehabilitation programs, with tasks such as teaching energy conservation, addressing activities of daily living, and breathlessness management, all contributing to improved outcomes in COPD.
Neck pain	19.42	24.1	Physical therapy is consistently recommended in the management of neck pain, with robust evidence supporting exercise-based interventions in treatment guidelines. Across guidelines, multidisciplinary approaches within the scope of occupational therapy, including education, self-management strategies, and psychological support are recognized as important, especially for chronic pain and disability.
Multiple sclerosis	19.25	27.0	The American Academy of Neurology guidelines explicitly mention physical therapy and multidisciplinary rehabilitation (which includes occupational therapy) as effective interventions for improving functional outcomes in multiple sclerosis. Additional systematic reviews and consensus statements also consistently support the use of OT and PT as part of comprehensive MS care, particularly for activity, participation, and quality of life improvements.
Rheumatoid arthritis	14.86	35.1	The American College of Rheumatology recommends comprehensive occupational therapy and physical therapy as integral components of RA management, with early and individualized referral to these services. OT and PT are shown to improve pain and physical function, preserve independence, and support work participation in this population.
Headache disorders	14.59	16.9	Several consensus statements, systematic reviews, and expert recommendations in the medical literature consistently recommend physical therapy as part of a multimodal approach for tension-type headache, cervicogenic headache, and migraine. Occupational therapy is included as part of a recommended multidisciplinary approach to address environmental and functional triggers, as well as to support behavioral modification and coping strategies.

Table 2: OT/PT Economic Impact on Healthcare

Multiple high-quality studies and systematic reviews support the cost-benefit of occupational and physical therapy for adults across a range of conditions and settings. 

Diagnosis and setting	Citation for study on the economic benefit	Statement from results/discussion
Post-stroke, Post-traumatic brain injury, Pre-/post-hip replacement Acute/Subacute	Economic Effects of Occupational Therapy Services for Adults in Acute and Subacute Care Settings: A Systematic Review. (2023)	The findings suggest that occupational therapy for adults poststroke and post–traumatic brain injury, acute discharge planning, and pre– and post–hip replacement is cost-effective.
Musculoskeletal Disorders Outpatient	Cost-Effectiveness and Outcomes of Direct Access to Physical Therapy for Musculoskeletal Disorders Compared to Physician-First Access in the United States: Systematic Review and Meta-Analysis (2021)	Direct access to physical therapy is more cost-effective, resulting in fewer visits than physician-first access in the United States, with greater functional improvement.
Low back pain Outpatient	Cost-effectiveness of physiotherapeutic interventions for low back pain: a systematic review (2020)	Excluding one study, all studies reported that the physiotherapeutic intervention was cost-effective compared with the control arm.
People with cognitive and/or functional decline (This included people with mild cognitive impairment, dementia, multiple sclerosis, Parkinson’s disease, Huntington’s disease, motor neurone disease, arthritis, frailty, falls and hip fracture) Various settings	Economic evaluations of occupational therapy approaches for people with cognitive and/or functional decline: A systematic review (2018)	The findings of this review suggest that there are trends towards the economic benefit of systematic, or multicomponent, occupational therapy interventions for people experiencing cognitive and/or functional decline.
Osteoarthritis of the hip or knee Outpatient	Incremental clinical effectiveness and cost effectiveness of providing supervised physiotherapy in addition to usual medical care in patients with osteoarthritis of the hip or knee: 2-year results of the MOA randomised controlled trial (2018)	Individually supervised exercise (physio)therapy is cost-effective and clinically effective in addition to usual medical care at 2-year follow-up, and leads to cost savings for the health system and society.
Adults with multimorbidity Primary Care	Cost-effectiveness of an occupational therapy-led self-management support programme for multimorbidity in primary care (2018)	The OPTIMAL intervention appeared to be cost-effective relative to usual care at 6 months follow-up for the full patient population.
Heart failure, pneumonia, and acute myocardial infarction Acute Care	Higher Hospital Spending on Occupational Therapy Is Associated With Lower Readmission Rates (2017)	We found that occupational therapy is the only spending category where additional spending has a statistically significant association with lower readmission rates for all three medical conditions.  (And OT was only .3% of spend.)
Independent-living older adults Community	Cost-effectiveness of preventive occupational therapy for independent-living older adults (2002)	Preventive OT demonstrated cost-effectiveness in conjunction with a trend toward decreased medical expenditures.

Figure 1: Visualizing the Inflation-Adjusted Medicare Reimbursement for OT/PT

This data is visualized from the Physician Fee Schedule search tool for MAC Location: Nebraska. All values shown are adjusted for inflation to reflect 2025 dollars, using the Bureau of Labor Statistics CPI Inflation Calculator.

Figure 2: Visualizing the Decrease in OT School Applications 

Data is visualized from the AOTA 2022-2023 Academic Annual Data Report. 

Figure 3: Visualizing OT’s Role in Prevention

This figure is a core component to OT Potential’s description of occupational therapy, and showcases our role at the various levels of prevention. 

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