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On April 25, 2019, the Centers for Medicare & Medicaid Services (CMS) published a notice of proposed rulemaking that would revise the definition of group physical, speech and occupational therapy to allow six residents, rather than four, to participate in a group therapy session. If finalized, the rule would place even more nursing home residents at risk of receiving less individualized therapy. The Center for Medicare Advocacy (The Center) and the Long Term Care Community Coalition (LTCCC) have written comments detailing our concerns:

  • Under the Patient Driven Payment Model (PDPM), which will be implemented in October 2019, Medicare reimbursement will be based on patient characteristics and not therapy minutes. As a result, nursing homes will have a financial incentive to provide the least costly mode of therapy possible to residents, rather than the highest quality for each individual.
  • While only 25 percent of a resident’s therapy regimen, by discipline, can be provided in group or concurrent therapy, CMS makes clear that there “will be no penalty for exceeding the 25% combined . . . therapy limit.” This failure to properly enforce the group therapy limit means that nursing homes will not be held accountable for putting financial incentives over resident care.
  • By revising the definition of group therapy to allow more residents to participate in one group therapy session, CMS will make it easier for nursing homes to forgo individual therapy for even more residents at one time and without meaningful accountability.

Comments are due on June 18th.

To access our comments, please visit

If your organization would like to sign-on to our comments, please contact Dara Valanejad, Policy Attorney (Center & LTCCC), at or 202-293-5760.

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