Comment Letter on CMS Updates to Medicare Physician Fee Schedule

Executive Summary

CMS continues to identify opportunities to advance adoption of accountable, whole-person care to improve outcomes and overall health through iterative updates to the PFS over the years. Notably, the PFS provides an opportunity to scale innovations tested through the CMS Innovation Center (CMMI) and create a sustainable pathway to accelerating adoption of accountable care. The CY 2026 PFS builds on innovations to date, at a time when accountable care is at an inflection point. Our comments focus on provisions related to advancing whole-person, advance accountable care reflect on key pillars of the CMMI’s strategy to build healthier lives, as well and CMS’ commitment to creating a Health Technology Ecosystem to reduce care fragmentation and align efforts to provide comprehensive, whole-person care across the health care system. Overall, we commend CMS for its continued efforts to address fraud waste and abuse in the Medicare program through proposed changes to payment for skin substitutes. Additionally, we appreciate CMS’ commitment to moving towards more advanced risk-based models to advance accountable care adoption through provisions including the proposal to increase the conversion factor for clinicians participating in advanced accountable care models (AAPMs) and the proposal for earlier adoption of two-sided risk in the Medicare Shared Savings Program (MSSP).

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