The Alliance of Specialty Medicine submitted comments on the CY 2027 Medicare Physician Fee Schedule (PFS) proposed rule, opposing policies that further destabilize specialty physician practices and threaten patient access.
The Alliance expressed deep concern about ongoing reductions in Medicare payments to physicians, particularly as practice costs and inflation continue to rise. They argued that CMS’s approach of establishing new coding and payment for primary care, care management, and preventive services – and now “lifestyle” medicine – while reducing payments for specialty care to maintain budget neutrality, threatens the financial stability of specialty practices and could ultimately limit patient access to necessary specialty care. The Alliance urged CMS to avoid further redistributive cuts and instead prioritize policies that strengthen the Physician Fee Schedule for all physicians until broader payment reform is enacted by Congress.
The Alliance also opposed several proposed policies, including significant changes to the indirect practice expense methodology and a proposed payment reduction when evaluation and management (E/M) services are billed with modifier -25 on the same day as a “global” procedure. They argue that these proposals lack sufficient data and transparency and could disproportionately harm specialty practices. Similarly, the Alliance criticized proposals to establish payment for new services like Shared Medical Appointments and Health Coaching without adequate evidence of their benefit or safeguards against fraud and overutilization.
Additionally, the Alliance called for improvements to the Quality Payment Program (QPP), advocating for voluntary rather than mandatory reporting pathways, more meaningful specialty-specific quality measures, and a balanced transition to digital quality measurement. They also support extending telehealth flexibilities and urge CMS to provide clear guidance on new telehealth requirements.
Throughout their comments, the Alliance emphasized the need for data-driven, transparent policy changes that do not shift resources away from specialty care, and called for collaboration with specialty societies to ensure that new payment and reporting requirements do not create undue administrative burdens or threaten the viability of independent specialty practices. You can read the complete comment letter by clicking on the link below.
