Major Wins for Therapy Providers in the 2025 Medicare Physician Fee Schedule

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The 2025 Medicare Physician Fee Schedule marks another pivotal moment for therapy providers, delivering a combination of long-awaited progress and lingering challenges.

On Friday, November 1, 2024, the U.S. Center for Medicare & Medicaid Services (CMS) released the 2025 Physician Fee Schedule Final Rule, with some major wins for therapy providers as well as some bad news sprinkled in.

First, the Bad News: Payment

The 2025 Medicare Physician Fee Schedule Final Rule finalizes a 2.8 percent cut to reimbursement, continuing the worrying trend of a nearly 30 percent decrease in Medicare payments in the past 20 years. This continued downward pressure on payments threatens to reduce overall access to care for older adults as fewer doctors, clinicians, and other healthcare professionals may choose to accept Medicare as a result of unsustainably low payments for care.

Industry advocates have reacted strongly to the cut. American Medical Association President Dr. Bruce Scott stated, “To put it bluntly, Medicare plans to pay us less while costs go up. You don’t have to be an economist to know that is an unsustainable trend, though one that has been going on for decades.” Scott also highlights the impact of the cuts for patient access: “For physician practices operating on small margins already, this means it is […] harder to take on new Medicare patients, and harder to keep the doors open, particularly in rural and underserved areas.”

The AMA has commented and engaged regularly with CMS on the issue of fee schedule reform—as have many advocacy groups, to no avail. The APTA recommends that providers reach out to their lawmakers to support the Medicare Patient Access and Practice Stabilization Act of 2024. To learn more and contact your lawmakers, visit the APTA’s advocacy page on fee schedule reform.

Major Win on Supervision

CMS has finalized general supervision for physical therapist assistants and occupational therapy assistants in the private practice setting under Medicare Part B. This is a major win, building on last year’s change allowing general supervision for remote therapeutic monitoring. The 2025 Medicare Physician Fee Schedule takes that further and extends general supervision for all areas of care.

Telehealth in Jeopardy

While supervision requirements improved, the 2025 Medicare Physician Fee Schedule did not extend telehealth flexibilities introduced during the public health emergency. As a result, PTs, OTs, and SLPs will not be eligible providers of telehealth as of January 1, 2025. Restrictions on site of service and geography will be restored to their pre-pandemic state as well—unless Congress can act in time. We strongly encourage providers to reach out to their lawmakers directly or through the APTA’s patient action center.

Major Win on Plan of Care Certification

Therapy providers have long been challenged by the requirement to collect the physician’s signature on the plan of care for patients referred to therapy. This requirement has needlessly caused many disruptions to care, as without the signature within 30 days the provider will not be paid.
Primary care physicians are not experts on therapy documentation and often don’t understand this requirement, commonly leading to problems requiring education and outreach—and more of a therapy provider’s time just to get paid for the care they’ve already provided. CMS has finalized a change that will allow therapy providers to simply transmit the plan of care (renamed “plan of treatment”) as long as the referral and POC are documented, the therapy providers requirement has been met, and their claims can no longer be denied on this basis.

Navigating the changes in the 2025 Medicare Physician Fee Schedule

The 2025 Medicare Physician Fee Schedule reflects a balancing act—some much-needed wins alongside ongoing challenges that therapy providers cannot afford to ignore. While the finalized rule introduces practical improvements, it also signals areas where vigilance and advocacy will remain critical in the months ahead.

For therapy providers, the changes to supervision requirements and plan of care certification will help alleviate common administrative bottlenecks. These updates offer more breathing room, making it easier to focus on what matters most: delivering care. But alongside these wins are pressures that can’t be overlooked. Reimbursement cuts and the return of pre-pandemic telehealth restrictions could have far-reaching consequences, particularly for access to therapy services.

Staying informed on the details of the 2025 Medicare Physician Fee Schedule and understanding how these changes impact your practice is the first step. From there, engagement—whether through adapting workflows or advocating for reforms—will be key to navigating this shifting landscape and continuing to serve patients effectively.

To learn more about the changes in the 2025 Medicare Physician Fee Schedule, review the press release, factsheet and final rule.