Everyone hates unnecessary paperwork and red tape—it cuts into your time with patients, adds to a clinician's workload, and often can delay care. The Centers for Medicare & Medicaid Services (CMS) seems to have gotten the message, going so far as to propose a rule on reducing administrative burden. And you have an opportunity to weigh in on the issue: CMS is asking for public comment on regulatory burdens as it considers ways to streamline processes in future rules. Comments are due by November 19.

Carol Zehnacker, PT, DPT, has worked in a multitude of practice settings, including acute care, skilled nursing facilities, home health, and private practice. Zehnacker says, "There has been an explosion of regulations and administrative burdens that hamper our ability to provide quality care, and can lead to provider burnout."

"We all went into this profession with a desire to help others," says Theresa Marko, PT, DPT, MS. "The health care system sometimes inhibits progress due to unnecessary regulations. How do we fix any of this? How can one person make a difference? APTA has a team of people working to improve the system in which we operate. If we can rally together with one collective voice to let the powers that be know how we feel, wouldn't that be great? For this proposed rule, APTA has created an easy-to-use template you can download, edit with personalized comments, and send in to CMS."

Both Zehnacker and Marko are submitting comments using APTA's template, which provides therapists with some specific content areas they can customize by providing their personal stories and highlighting other regulations that are overly burdensome on physical therapists. The content areas in the template letter include the following:

  • Streamline the Medicare credentialing process.
  • Institute a permanent moratorium on the direct supervision requirement for outpatient physical therapy services in critical-access hospitals.
  • Eliminate or modify the outpatient therapy plan of care 30-day initial certification and 90-day recertification requirements.
  • Eliminate prior authorization for Medicare Advantage patients or require same-day authorizations.
  • Better ensure accurate beneficiary eligibility data.

In her comments to CMS, Zehnacker, a private practice owner who has a contract with a home health agency, described the "unnecessary requirement" of notifying the physician when the plan of care changes, such as a missed visit or a treatment or service as required by the plan of care. "This is time consuming for both the therapist and the staff at the physician's office. The physician has already ordered physical therapy in the home health setting. In reality, it is the physical therapist who develops the physical therapy plan of care and awaits the physician's sign-off."

You don't have to go to Capitol Hill to make your voice heard. Rather, you can use your voice, through written comments, to educate and influence executive and independent agencies, the bodies that create or publicize regulations by the authority of Congress.

"When regulatory agencies propose to take action on a certain subject that is of interest to you, it's important to take that opportunity to use your voice," says Kara Gainer, APTA's director of regulatory affairs. "It's the individuals who often provide the most compelling comments, offering the agency a different perspective that is both personal and closely connected to the issue at hand."

Although comments submitted by APTA, representing the physical therapy profession, are incredibly influential, "when CMS is making important decisions that will affect our everyday operations in our professions, they will take into consideration all the comments submitted by providers," says Marko. "Personalizing APTA's template and uploading it to the CMS website is easy—I was able to do it in about 15 minutes! As a private practice orthopedic PT I have experienced much unnecessary burden throughout my career. The template is an easy way for all of us to impact the system in which we operate and produce a positive outcome."

Visit APTA's website to download the template and submit your comments. (Scroll down to "CMS Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction.")