this is the default page template

AHPA submitted comments on: CY 2026 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments (CMS 1832-P). Click here for the full comment letter. Below are some key takeaways.

• Protect physician reimbursement and avoid additional payment reductions: AHPA urges CMS not to compound existing payment pressures through reductions to Relative Value Units, changes to the practice expense methodology, or the proposed efficiency adjustment. AHPA warns that further cuts to facility-based services and hospital-employed physicians could weaken the health care workforce, make physician recruitment more difficult for rural hospitals, and limit patients’ access to care.
• Modernize skin-substitute payments while preserving clinical flexibility and protecting ACOs: AHPA supports CMS’s effort to address unsustainable spending growth and inconsistent utilization of skin substitutes. It recommends allowing ACOs to select products based on clinical need and real-world evidence, exploring tiered payments tied to outcomes and cost-effectiveness, and excluding questionable skin-substitute spending from historical MSSP benchmarks and financial calculations.
• Refine the Ambulatory Specialty Model to reward meaningful improvement without jeopardizing patient access: AHPA supports expanding specialty-focused alternative payment models but recommends using external quality benchmarks, removing topped-out measures, limiting negative payment adjustments for improving clinicians, and reducing duplicative reporting. It also urges CMS to exclude ASM payment adjustments from MSSP reconciliation to prevent double counting and closely monitor whether specialists withdraw from serving Medicare patients.
• Strengthen the Medicare Shared Savings Program through realistic risk timelines and greater flexibility: AHPA supports moving ACOs toward risk-bearing arrangements but recommends preserving a manageable glide path, particularly for newer and rural organizations. Its recommendations include delaying accelerated risk for the 2022 ACO cohort, expanding rural and beneficiary-threshold flexibilities, improving change-of-ownership and quality-reporting policies, integrating specialists more effectively, and creating lower-risk pathways into Advanced Alternative Payment Models.
• Expand access to preventive and digital tools through sustainable reimbursement and realistic implementation standards: AHPA supports CMS’s proposed modernization of the Medicare Diabetes Prevention Program, including virtual delivery and self-reported weights. It also recommends establishing payment methodologies that recognize the cost and value of software-as-a-service and artificial intelligence tools. For digital quality measurement, AHPA urges CMS to standardize electronic health record data, tailor reporting to ACOs’ unique structures, provide technical resources, and extend the proposed FHIR-based reporting transition from two years to at least four years.