OT/ PT Comment Letter for Tiered Complexity Reimbursement in 2027

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 our entry-level education to the master’s and doctoral levels.

And yet, our treatment code set has remained largely unchanged.

In 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.

✅ 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 the structural barrier holding back our incredible workforce, opening the door for us to meet the complex needs of this next era of care—the very work we were educated 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 by using the template below: Copy and paste the quick template below directly, or personalize the full version with your own professional insights. Be sure you include the proper formatting as demonstrated below.

2. Access the Portal: Go to the Regulations.gov 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: On “What is Your Comment About?”, select Occupational Therapist or Physical Therapist.

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 is short enough to drop in the 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 5000 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 respond particularly to CMS’s Request for Information on Redesigning Primary Care, Request for Information on Alzheimer’s Disease and Related Dementias, 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 as we consider how to respond helpfully: 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: assessing changing presentations, modifying care plans, and coordinating 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 pay the existing evaluation complexity levels differentially, keeping low-complexity evaluations at their current rate while properly valuing moderate- and high-complexity assessments to match their true time and clinical judgment.

CMS should recognize therapist clinical management.

Beyond the initial evaluation, licensed OTs and PTs perform clinical reasoning throughout an episode of care that currently has no clear billable expression: 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.”]

My recommendations.

I respectfully ask CMS to:

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

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

If you have more than 5 minutes, you may want to submit a longer version that truly speaks to your professional experience.

1. You can access the full comment letter template in this google doc.

2. Make a copy and personalize the highlighted sections.

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

4. Upload as a PDF to regulations.gov.

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 that supports these requests. This letter will be submitted before the comment period ends on September 14th, then shared in its entirety here.

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