2027 CMS Comment Template: Top-of-License OT & PT Care

The occupational and physical therapy professions have changed substantially since the 1990s. To meet the complex needs of an aging population, we’ve expanded our workforce and raised entry-level education for therapists to the master’s and doctoral levels.

And yet, our treatment code set has remained largely unchanged—hindering our ability to practice at the top of license and deliver the level of care our workforce is capable of. We lay out the full problem in our post: How OT & PT are Blocked from Serving Older Adults.

After releasing this year’s Physician Fee Schedule proposed rule, The Centers for Medicare & Medicaid Services (CMS) is actively seeking input on how to better describe and value care for complex patients.

It could not be more urgent that you—and every OT and PT you know—submit a comment.

Specifically, we urge you to join our effort to advocate for two key asks:

✅ We believe therapists need a small set of non-time-based management codes to reflect the ongoing clinical reasoning and longitudinal care we provide.

✅ We also believe our existing evaluation codes should be reimbursed differentially based on complexity.

These simple updates would remove major structural barriers holding back our incredible workforce, opening the door for us to meet complex patient needs in this next era of care—the very work we were trained to do in the first place.

We’ve created a simple template to make sharing your voice with CMS quick and easy. You can make your voice heard with just 5 minutes of your time.

5 steps for submitting your comment letter

1. Prepare your comment letter using one of our templates: Copy and paste the short template below directly into the text box provided on the comment page, or personalize the full version (available here) with your own professional insights and upload it as a PDF. Be sure to include the proper formatting as demonstrated in each template.

2. Access the portal: Go to the Regulations.gov comment page before September 14, 2026.

3. Start your submission: Use the prominent blue Comment button to open the public comment interface and share your comment.

4. Select your category: Select “Occupational Therapist” or “Physical Therapist” in the “What is Your Comment About?” section.

5. Upload and finalize: Either paste your text directly into the provided comment box or upload your letter as a PDF attachment. Review your details, submit your official comment, and celebrate your advocacy win! 🎉

Copy & Paste Quick Template

This template is short enough to enter directly into the comment text box! Just add your personal details, go to this page, and drop it in!

Don’t forget to change the highlighted portions. Note that there is a 5,000-character limit on copy/paste submissions.

RE: Comments on Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P)

Dear Administrator Oz:

I am a [occupational therapist / physical therapist / occupational therapy assistant / physical therapist assistant / other] practicing in [setting and state]. My comments specifically address CMS’s Request for Information on Redesigning Primary Care, Request for Information on Alzheimer’s Disease and Related Dementias, and Request for Information on the Coding System and Valuation (and its questions regarding reconfiguration of the Care Management Code Family).

Together, these sections raise an important question for occupational and physical therapy: Does the Medicare Physician Fee Schedule accurately describe and pay for the work our professions currently perform, particularly for complex Medicare beneficiaries?

I do not believe it does.

Our code set no longer reflects our work.

Most outpatient therapy services are still paid through 15-minute, activity-based codes (such as therapeutic exercise or self-care training) that fail to capture the advanced clinical judgement required of modern practitioners who regularly assess changing presentations, modify care plans, and coordinate complex care.

These professions have also evolved substantially since this code structure was developed. Occupational therapy is now a master’s-entry profession and physical therapy a doctoral-entry profession, working alongside skilled assistant workforces who are trained to deliver much of the treatment represented by the existing activity-based codes.

Our payment system should better distinguish between basic treatment delivery and the clinical reasoning and management work of the licensed therapist.

Complex patients need a payment structure that supports complex care.

This problem is most apparent when caring for Medicare beneficiaries with dementia, frailty, multiple chronic conditions, progressive neurological disease, recurrent falls, or substantial caregiver needs.

The existing low-, moderate-, and high-complexity occupational and physical therapy evaluation codes are paid at essentially the same rate.

I ask CMS to reimburse the existing evaluation complexity levels differentially, keeping low-complexity evaluations at their current rate while properly valuing moderate- and high-complexity assessments to match the time and clinical judgment required to complete them.

CMS should recognize therapist clinical management.

Beyond the initial evaluation, licensed OTs and PTs perform clinical reasoning throughout an episode of care with no clear way to bill for it: reassessing the patient, modifying the plan, analyzing risk, coordinating care, evaluating caregiver capacity, and deciding what can appropriately be delegated.

I ask CMS to consider creating a small family of non-time-based therapist management codes that could be reported by licensed OTs and PTs to recognize this longitudinal clinical decision-making.

See more rationale behind both requests in the full comment letter from OT Potential.

What this looks like in my practice.

[ADD 3–6 SENTENCES FROM YOUR OWN EXPERIENCE.]

You might describe:

[A patient or type of patient you routinely see who requires significant clinical reasoning, reassessment, caregiver involvement, risk management, or coordination with other providers. Explain what you did, why it mattered to the patient, and why the current 15-minute activity-based payment structure does not adequately reflect that work.]

For example:

[“I recently treated a Medicare beneficiary with ________. The most important work I performed was not simply ________. I had to ________. Under the current code structure, much of that clinical reasoning and coordination is either difficult to report or not separately recognized at all. This is exactly the type of patient I believe Medicare should make it easier, not harder, for therapists to serve.”]

Here are my recommendations.

I respectfully ask CMS to:

1. Pay the existing low-, moderate-, and high-complexity occupational and physical therapy evaluation codes differentially, while approximately maintaining the current payment for the low-complexity tier.

2. Develop a small family of non-time-based therapist management codes that recognize the ongoing clinical reasoning, reassessment, risk management, care coordination, and plan-of-care modification performed by licensed occupational and physical therapists.

3. Preserve the existing timed treatment codes so occupational therapy assistants and physical therapist assistants can continue delivering skilled treatment within their appropriate scope.

These changes would allow Medicare to better distinguish between lower-complexity treatment delivery and the higher-level clinical work required to manage complex patients.

Occupational and physical therapists are already trained to help Medicare beneficiaries remain functional, independent, and safely at home. The Physician Fee Schedule should give us a way to describe and be paid for that work.

Thank you again for the opportunity to comment and for considering these recommendations.

Sincerely,

[Name, credentials]
[Optional title / organization]
[City, State]

Full Letter Template to Upload as a PDF

If you have more than 5 minutes, we encourage you to submit a longer version that truly speaks to your professional experience. Uploading your comment as a PDF allows you to add as much detail as you want, because there is no character limit. So if you have the time, this direction is totally worth it! Here’s how to do it:

1. Access the full comment letter template in this Google Doc.

2. Make a copy of the document and personalize the highlighted sections. (To make a copy, click “File” in the top menu bar and select “Make a copy.”)

3. Include personal insights from your own practice, if applicable.

4. Download your personalized comment letter as a PDF by clicking “File” in the top menu bar, selecting “Download,” and choosing “PDF Document.”

5. Upload your PDF via regulations.gov before September 14, 2026.

Coming Soon: OT Potential Official Comment Letter

Here at OT Potential, we are drafting our own comprehensive comment letter that dives deep into the detailed evidence supporting these requests. This letter will be submitted before the comment period ends on September 14, 2026, and we will share the draft in its entirety here.

Check back to see this massive advocacy effort in full, and to get updates on the proposed rule once the comment period ends.