AHPA submitted comments on: CY 2027 Physician Fee Schedule and related Medicare payment and coverage policies [CMS-1848-P].

Click here for the full article. Below are some key takeaways.

  • Physician payment reductions: AdventHealth opposes further reductions under the Physician Fee Schedule, including proposed conversion factors of $33.16 for qualifying APM participants and $32.84 for nonparticipants. The system warns that continued cuts could threaten provider viability and patient access.
  • Orthopedic services: The system urges CMS to reconsider proposed work RVU reductions of approximately 17% to 20% for hip, knee and shoulder replacements and instead retain current values while reviewing the underlying data. AdventHealth warns that the cuts could reduce Medicare participation and lengthen waits for orthopedic care.
  • Coding and care delivery: AdventHealth supports enhanced payment for complex, longitudinal care delivered through Medicare ACOs and new billing codes for advance care planning performed by clinical staff. However, it recommends flexible supervision policies, including virtual or general supervision, to avoid limiting access.
  • Rural and remote care: The system supports allowing Rural Health Clinics to separately bill for diabetes self-management training and medical nutrition therapy. It opposes requiring remote-monitoring staff to be direct employees of the billing practice, warning that the policy could force providers to scale back services, particularly in rural communities.
  • 340B reporting: AdventHealth asks CMS not to make the new Medicare Part D 340B claims repository mandatory in 2027, citing overlapping federal reporting requirements, implementation costs and the risk of severe penalties for routine reporting errors. 
  • Medicare Shared Savings Program: The system supports several proposed ACO improvements, including increasing the BASIC Level E shared-savings rate from 50% to 60%, simplifying beneficiary notifications and providing more flexible quality and interoperability reporting. It also asks CMS to avoid changes that could disadvantage efficient or medically complex ACOs.
  • Primary care redesign: AdventHealth supports moving gradually toward prospective and population-based primary care payments, with voluntary hybrid capitation viewed as more feasible than full capitation. The system recommends adequate funding, risk adjustment, phased implementation and simpler billing requirements.
  • Technology and AI: The system recommends dedicated reimbursement for technology and AI that expands clinician capacity, along with nationwide regulatory consistency, clear clinical-use guidelines and legal protections that would help practices adopt these tools.