Comment on CMS-2026-2377-0001

To the Centers for Medicare & Medicaid Services: I am writing on behalf of an independently owned outpatient physical therapy organization serving patients in central, southern, and northeast Arkansas, including rural communities. I respectfully urge CMS to reconsider payment policies in the CY 2027 Medicare Physician Fee Schedule that would reduce the conversion factor or otherwise fail to account adequately for the rapidly rising cost of delivering outpatient rehabilitation services. We appreciate CMS’s efforts to improve the accuracy of relative value units for physical and occupational therapy. However, the proposed reduction in the Medicare conversion factor remains deeply concerning. CMS projects that the nonqualifying-APM conversion factor will decline by 1.68%, from $33.5875 in 2026 to approximately $33.02 in 2027. Although CMS’s specialty-impact table estimates a positive impact from changes to PT and OT relative value units, that table does not incorporate the separate reduction in the conversion factor. The ultimate effect on individual practices will depend on their service mix, geographic adjustments and other payment policies. For independently owned clinics, even a nominal increase that falls below the rate of practice-cost inflation functions as a reimbursement cut in real terms. Our expenses are not remaining flat. Payroll, employee benefits, rent, technology, compliance, cybersecurity, supplies and professional services continue to increase. Unlike large health systems, small and independently owned practices generally cannot spread these expenses across numerous departments, facilities and service lines. We also have limited ability to negotiate higher rates, and Medicare reimbursement frequently influences payment from other insurers. The cumulative effect of inadequate Medicare updates is therefore much greater than the effect of a single year’s percentage change might suggest. The consequences are especially serious in rural communities. Rural clinics often operate with smaller patient populations, greater staffing challenges and fewer opportunities to gain efficiencies through volume. They may also care for patients who have transportation limitations, complex health conditions and few alternative rehabilitation providers nearby. When an independent rural clinic reduces services, stops accepting Medicare beneficiaries or closes, patients may have to travel considerable distances—or may simply go without care. Outpatient physical therapy helps Medicare beneficiaries remain mobile, independent and safe in their homes. It supports recovery from surgery and illness, reduces fall risk, manages pain, addresses chronic disease and can help patients avoid more intensive and expensive services. Payment policy should recognize not only the immediate cost of a therapy visit, but also the broader value of maintaining access to timely, community-based rehabilitation. I respectfully ask CMS to: Avoid any net reduction in payment for outpatient physical therapy services in CY 2027, including reductions caused by the conversion factor or changes affecting commonly provided therapy services. Evaluate the combined effect of all proposed policies, rather than relying solely on specialty-level RVU estimates that exclude conversion-factor changes. Incorporate current practice-cost data reflecting actual increases in wages, benefits, insurance, technology, compliance and other operating expenses. Conduct and publish a rural-access impact analysis addressing the effect of payment changes on independently owned clinics and the Medicare beneficiaries who rely upon them. Work toward a predictable, inflation-sensitive payment methodology so that practices can recruit clinicians, invest in their workforce and continue serving Medicare beneficiaries. Our organization is committed to caring for Medicare patients. However, commitment cannot indefinitely overcome a payment system in which reimbursement fails to keep pace with the cost of providing care. Year-over-year financial pressure eventually forces practices to make difficult decisions concerning staffing, locations, appointment availability and Medicare participation. Those decisions ultimately affect patients. I urge CMS to use the final rule to protect beneficiary access and strengthen, rather than weaken, the viability of independently owned outpatient physical therapy practices, particularly those serving rural America. Thank you for considering these comments.