Physicians are asking for greater certainty around Medicare reimbursement, arguing that compounding payment decreases over time have drastically increased the pressure on practices.
Industry organizations, individual physicians and others weighed in through comments on the proposed Physician Fee Schedule, which were due on Friday. The proposed legislation would bump up payments by 3.62% next year, accounting for a 2.5% payment adjustment under the One Big Beautiful Bill Act.
In its comments (PDF), the Medical Group Management Association acknowledged the pay increase but said that the long-term trend remains a concern. The group noted that a 2.83% payment cut for 2025 has proven a challenge throughout the year.
“Reductions in Medicare reimbursement over the years have compounded well-documented administrative and financial pressures facing medical groups, which have only grown more pronounced because of the 2.83% Medicare payment cut that has been in place all of 2025,” MGMA wrote in its comments.
“Outdated budget neutrality policies, coupled with a lack of an inflationary update, undermine the ability of physician practices to remain financially viable,” the organization said.
MGMA is also asking the Centers for Medicare & Medicaid Services to extend telehealth flexibilities that are set to run out at the end of September, and to make permanent a current Medicare policy that allows physicians to list the location of their practice when billing for telehealth services they conducted while in their home.
The group said that reversing this policy could “lead to security concerns” and also increases the documentation burden.
The comment letter also calls for CMS to work with lawmakers to identify ways to overhaul the Merit-Based Incentive Payment System, or MIPS. MGMA said that physicians face a significant administrative burden under MIPS that should be addressed.
The group also is asking CMS to maintain the performance threshold in MIPS at 75.
“CMS should ensure its methodology avoids unsustainable increases to an already high threshold,” MGMA wrote.
The American Medical Association echoes many of MGMA’s concerns in its own comment letter. The organization argued that while there have been temporary updates to the fee schedule’s conversation factor in the past several years that increase payments, a more permanent solution to support docs is needed.
Medicare payments to physicians have stagnated, AMA said, even as the cost to run a practice has continued to climb.
“Inadequate physician payment has real-world consequences, accelerating the trend in consolidation and worsening seniors’ access to care,” AMA said. “To protect Medicare for the next generation, we urge the Trump Administration to support any congressional action to enact inflation-based updates for physician payments.”
A provision tying payment updates to the Medicare Economic Index was included in the House’s version of the reconciliation package, but did not make it into the final legislation.
AMA also pushed for similar changes to MIPS in its comment letter, urging CMS to maintain the performance threshold at 75 and make changes to how it calculates claims-based quality measures. The organization also said it is “disappointed” that the proposed fee schedule does not tackle data access issues in the program, as physicians typically receive an annual MIPS report that could include feedback from months after a patient visit.
“While CMS put forward several positive changes in the 2026 MPFS proposed rule, there is more red tape to be cut,” AMA said.
Other organizations called for CMS to continue making refinements to the Medicare Shared Savings Program. The National Association of ACOs said in its comment letter that the agency should ensure the program has sustainable financial benchmarking by taking steps like addressing the ACO benchmark ratchet and removing the Accountable Care Prospective Trend.
NAACOs also noted that CMS has taken steps in recent years to align MSSP quality reporting with MIPS, and that’s led to increased burden and lost incentives.
The agency can also promote innovation with MSSP by incorporating all waivers from its Innovation Center into the program, and making it easier for ACOs to test additional waivers across models.
“Accountable care empowers patients and providers with tools to focus on prevention, manage chronic conditions, expand access to services not traditionally covered by Medicare, and reduce overall costs,” NAACOs said. “Ultimately, accountable care is a strong vehicle to meet the objectives of Making America Healthy Again.”
In its comments, Premier similarly recommended that CMS focus on continuing to refine enhancements to MSSP, and said the agency should delay the acceleration of downside risk in the program by two years.
CMS should also consider a track in MSSP specifically for rural providers, and a higher-risk track option within the program.
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