APTA Template: Comment Template Letter - Medicare and Medicaid COVID-19 Rule Comment

Sep 2, 2026

Template letter for submitting electronic public comments to the Centers for Medicare and Medicaid Services regarding an interim final rule affecting Medicare and Medicaid Programs, Basic Health Program, and Exchanges during the COVID-19 public health emergency. The draft includes submission instructions, a dated letter header addressed to the CMS Administrator, and tailored comment content from a physical therapist (or related role) advocating permanent telehealth reimbursement flexibilities and requesting removal of the therapy plan of care certification requirement.

LanguageEnglish

CategoryLetters

FormatDOCX

Pages4

Reading Time2 min

AccessFree to download

Submission and Letter Header

Electronic comment submission instructions

Recipient, subject line, and opening paragraph

Core Comment Content

Make Telehealth Policies Permanent

Eliminate Therapy Plan of Care Certification Requirement

Address administrative and care-delivery burden

APTA Template: Comment Template Letter We suggest you submit comments electronically. You may submit electronic comments on the proposed rule here: HYPERLINK "https://www.regulations.gov/comment?D=CMS-2020-0047-0001" https://www.regulations.gov/comment?D=CMS-2020-0047-0001 Copy and paste your introductory paragraph into the comment box and attach this document as a file, which you can do below the comment box. ** REMINDER: DELETE THESE SUBMISSION INSTRUCTIONS AND ANY OTHER HIGHLIGHTED LANGUAGE BELOW PRIOR TO SUBMITTING YOUR COMMENTS _______________________________________________________________________ [MONTH & DAY], 2020 Seema Verma, MPH Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Room 445-G Attn: CMS-5531-IFC Hubert Humphrey Building 200 Independence Ave, S.W. Washington, D.C. 20201 Submitted electronically RE: Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program [CMS-5531-IFC] Dear Administrator Verma: I am writing in response to the request for comments on the Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program interim final rule with comment period. [INSERT A PARAGRAPH ABOUT YOURSELF, THE PHYSICAL THERAPIST SERVICES YOU PROVIDE, YOUR PRACTICE SETTING, AND THE PATIENTS YOU SERVE; OR YOUR STATUS AS A STUDENT AND AMBITIONS AFTER GRADUATION] As a [PHYSICAL THERAPIST/PHYSICAL THERAPIST ASSISTANT/PHYSICAL THERAPY STUDENT], I appreciate the opportunity to provide feedback to CMS on this interim final rule. I respectfully request that you consider my more detailed comments and recommendations provided below. Make Telehealth Policies Permanent I request that CMS permanently extend the policy that allows telehealth services furnished by all outpatient physical therapy providers, including physical therapists and physical therapist assistants in private practice, rehabilitation agencies, hospital outpatient departments, skilled nursing facilities, comprehensive outpatient rehabilitation facilities, home health agencies, and critical access hospitals to be reimbursed under Medicare. CMS must permanently implement the telehealth flexibilities afforded during the COVID-19 public health emergency to ensure that patients continue to have real-time access to physical therapists and physical therapist assistants in their home without barriers when a patient is unable or chooses not to receive onsite care. Telehealth also should be available to augment and reinforce face-to-face sessions based on patient and/or caregiver needs. Eliminate Therapy Plan of Care Certification Requirement Pursuant to Medicare Benefit Policy Manual Chapter 15 Section 220, a plan of care must contain diagnoses; long-term treatment goals; and type, amount, duration, and frequency of therapy services. CMS requires a physician (or nonphysician provider) to certify a patient’s therapy plan of care, with a dated signature on the plan of care, or with another document that indicates approval of the plan of care. The manual states that it is not appropriate for the physician to certify a plan of care if the patient was not under the care of a physician at the time of the treatment, or if the patient did not need the treatment. By certifying an outpatient plan of care for therapy, the physician is certifying that: services are or were required because the individual needed therapy; a plan for furnishing therapy has either been established by the physician or by the therapist providing such services, and is periodically reviewed by a physician; and services are or were furnished while the indivi

FAQs

How should comments be submitted according to the template?

Comments should be submitted electronically, with the introductory paragraph pasted into the comment box and the document attached below the comment box.

What does the template ask CMS to do about telehealth?

It requests CMS permanently extend COVID-19 telehealth flexibilities so telehealth services can be reimbursed under Medicare and support real-time access and reinforcement of face-to-face care.

What therapy documentation requirement does the template seek to eliminate?

It requests eliminating the therapy plan of care certification requirement, arguing it creates major administrative burden and can delay care delivery.

Sep 2, 2026

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