Comment on CMS-2026-2377-0001

Physical therapists are uniquely qualified to serve as primary care musculoskeletal providers because they are the healthcare professionals with the most extensive education and clinical training dedicated specifically to the evaluation and management of movement disorders and musculoskeletal pathology. Numerous studies have demonstrated that physical therapists can accurately screen for serious pathology, make appropriate referrals when necessary, and effectively manage the vast majority of musculoskeletal conditions while reducing unnecessary imaging, specialist visits, and healthcare costs. As the profession continues to advance through residency and fellowship training, physical therapists are developing expertise that extends beyond traditional rehabilitation. With formal post-professional training in musculoskeletal residency programs and competency-based education in diagnostic musculoskeletal ultrasound, electrodiagnostic testing, and other evidence-based diagnostic procedures, appropriately trained physical therapists can provide more precise diagnoses, guide targeted interventions, and identify patients who require medical or surgical referral. This elevates—not replaces—the collaborative role of physicians by ensuring patients reach the right provider at the right time. The conversation should not be whether physical therapists can serve as primary musculoskeletal providers—it should be how we continue to support advanced training, standardized credentialing, and evidence-based utilization of diagnostic testing within the profession. Raising awareness of these advanced practice pathways will improve access to timely, high-quality musculoskeletal care while maintaining patient safety through rigorous education and collaborative practice. Patients deserve providers who are not only experts in movement but also highly skilled in musculoskeletal diagnosis, and residency-trained physical therapists are well positioned to fulfill that role.