1. Select "Submit electronic comments on CMS Regulations with an open comment period"
2. Select "GO" under the submit comment column for Docket ID CMS-1385-P.
3. Please select the category that best suits you and your practice setting. 
4. Under organization, please list your employer's name, if possible.  Please do NOT list the NATA.  We are submitting our own comments and would like your comments viewed as practitioners'. 
5. Submit your comments. 

If you would like to read more information regarding the proposed changes, you can access them HERE

The pages from the Federal Register that are important are:

LETTER

Dear Sir or Madam:

BRIEF INTRO ABOUT SELF  ie.  Where you work, what you do, education, certification, etc.

I am writing today to voice my opposition to the therapy standards and requirements in regards to the staffing provisions for rehabilitation in hospitals and facilities proposed in 1385-P. 

While I am concerned that these proposed changes to the hospital Conditions of Participation have not received the proper and usual vetting, I am more concerned that these proposed rules will create additional lack of access to quality health care for my patients. 

As an athletic trainer, I am qualified to perform physical medicine and rehabilitation services, which you know is not the same as physical therapy.  My education, clinical experience, and national certification exam ensure that my patients receive quality health care.  State law and hospital medical professionals have deemed me qualified to perform these services and these proposed regulations attempt to circumvent those standards. 

The lack of access and workforce shortage to fill therapy positions is widely known throughout the industry.  It is irresponsible for CMS, which is supposed to be concerned with the health of Americans, especially those in rural areas, to further restrict their ability to receive those services.  The flexible current standards of staffing in hospitals and other rehabilitation facilities are pertinent in ensuring patients receive the best, most cost-effective treatment available. 

Since CMS seems to have come to these proposed changes without clinical or financial justification, I would strongly encourage the CMS to consider the recommendations of those professionals that are tasked with overseeing the day-to-day health care needs of their patients.  I respectfully request that you withdraw the proposed changes related to hospitals, rural clinics, and any Medicare Part A or B hospital or rehabilitation facility. 

Sincerely,