The Alliance of Specialty Medicine submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the CY 2026 Medicare Physician Fee Schedule proposed rule, raising concerns about inadequate payment updates that fail to keep pace with practice costs, the arbitrary efficiency adjustment, and changes to practice expense methodology that could inappropriately penalize independent facility-based physicians. The Alliance also cautioned that budget neutrality adjustments due to inflated E/M utilization assumptions, such as those tied to the complex care add-on code, G2211, have eroded the conversion factor, and urged CMS to make needed corrections. The specialty coalition also urged CMS to retain the traditional Merit-Based Incentive Payment System (MIPS) as a flexible and voluntary reporting option alongside MIPS Value Pathways (MVPs), and strongly opposed expansion of the Ambulatory Specialty Model. You can read the full letter to CMS by clicking on the link below:
