12 Sep The Task Force Provides Input to CMS on the CY 2026 Physician Fee Schedule Proposed Rule

The Health Care Transformation Task Force submitted comments on the Centers for Medicare & Medicaid Services (CMS) Medicare Physician Fee Schedule Proposed Rule (CMS-1832-P). The Task Force’s letter focuses on addressing proposals to the following: (1) Medicare Shared Savings Program, (2) Ambulatory Specialty Model, (3) Quality Payment Program, (4) Chronic Disease Prevention and Management, and (5) Enhanced Care Delivery. HCTTF also responds to several requests for information.  

Medicare Shared Savings Program 

• MSSP Risk Tracks: HCTTF supports CMS’ proposals to limit downside risk to the first five-year agreement period and accelerate the transition to higher levels of risk. HCTTF urges CMS to provide additional flexibility for rural, safety-net, and independent providers.  
• ACO Eligibility Expansions: HCTTF supports CMS’ proposals to address ACOs with fewer than 5,000 beneficiaries.  
• Primary Care Services Definition: HCTTF supports CMS’ proposal to include behavioral health services within the definition of primary care for ACO attribution. HCTTF asks that CMS continue to support health risk assessments code but to rename as “Upstream Factors Assessment Services.” 
• Quality Payment Program – Alternative Payment Model (APM) Performance Pathway: HCTTF is supportive of CMS’ efforts to align quality measure sets across programs. HCTTF urges CMS to help clinicians identify and address non-medical factors relevant to patients’ health.  
• Quality Payment Program – Advanced APMs: HCTTF supports CMS’ proposal to allow clinicians to qualify as individuals or as part of an APM entity. However, we are concerned that using all covered professional services, rather than E/M codes alone, may make it harder for many clinicians to qualify for these thresholds.  
• Beneficiary Eligible for Medicare CQM Definition: HCTTF supports CMS’ proposal to clarify the definition of beneficiaries ACOs must report on for Medicare CQMs. HCTTF opposes adding “reviewed” in both the breast cancer and colorectal cancer screening measures as this will increase documentation burden without adding value.  
• Health Equity Adjustment Removal and Terminology: HCTTF recommends that CMS retain and rename this adjustment as the “Population and Income Adjustment and Bonus Points.” 
• CAHPS Survey Administration Expansion: HCTTF supports CMS’ proposal to create a web-mail-phone protocol for CAHPS.  
• ACO Participant Change of Ownership: HCTTF supports CMS’ proposal because it would prevent disruptions in access and care delivery for patients.  
• Revision to the Extreme and Uncontrollable Circumstances (EUC) Policies: HCTTF strongly supports CMS’ proposals to expand EUC policies to include cyberattacks and apply to all assigned beneficiaries.  

Ambulatory Specialty Model

HCTTF supports the goals of ASM, and we believe this model may be a positive step in advancing specialist integration in VBC. We have several recommendations to refine the ASM design, including:

• Mandatory ASM Participation: HCTTF assesses support for mandatory models on a case-by-case basis. We believe mandatory models can serve an important role in driving model participation. However, we recommend that specialists participating in Advanced APMs be exempt from ASM, to create incentives for specialists to join global risk models. 
• ASM scoring: HCTTF is generally supportive of CMS’ proposals related to quality measures and performance. However, HCTTF recommends several key changes to more effectively incentivize and more accurately measure specialist performance, including: (1) raise the low volume threshold to 30, (2) reduce lag time in payments, (3) set thresholds in advance, and (4) provide data to specialists.  

Quality Payment Program & Interoperability  

• MIPS Value Pathways (MVPs): HCTTF continues to support the underlying concept behind MVPs, and we see the value in a mechanism that creates a glidepath for providers to participate in Advanced APMs. HCTTF offers several recommendations for strengthening the MVP program.  

Chronic Disease Prevention & Management 

• Skin Substitutes: HCTTF supports CMS’ efforts to eliminate waste, fraud, and abuse related to skin substitutes. CMS should remove skin substitutes and other fraudulent payments from benchmark and performance year financial calculations for performance years 2025 and prior.  
• Medicare Diabetes Prevention Program (MDDP): HCTTF supports the proposed changes to MDPP, which will increase access to this evidence-based program to prevent and treat diabetes.  

Enhanced Care Delivery 

• Advanced Primary Care Management & Behavioral Health: HCTTF believes that the future of primary care payments should not rely solely on code-based reimbursement. We recommend that CMS continue efforts to invest in primary care, streamline billing processes, and move away from the inefficiencies of traditional FFS through the advancement of more hybrid and population-based payment models that occur in conjunction with accountable care arrangements.  
• Telehealth: HCTTF is broadly supportive of CMS’ proposals to streamline and increase access to telehealth services. Granting all services permanent status on the Medicare Telehealth Services List is particularly important because it provides stability, ensuring that providers investing in telehealth technology will be able to continue billing those codes in future years.  
• Home-Based Care: HCTTF strongly supports CMS’ proposal to empower primary and preventive care particularly for complex patients who are living in nursing homes and other residential settings.  

Read the Letter Here