Mehmet Oz, MD
Administrator
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue SW
Washington, DC 20201
Submitted electronically via www.regulations.gov
RE: Medicare and Medicaid Programs; CY 2027 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program
Dear Administrator Oz,
The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty physicians across 15 specialty and subspecialty societies. The Alliance is deeply committed to improving access to specialty medical care by advancing sound health policy, which has guided our response to CMS’ proposals in the aforementioned rule on behalf of the undersigned members. Because many of CMS’ major proposals affect Alliance member specialties differently, our comments focus on the fundamental policy issues that cut across all of our specialties, with the expectation that each member society will submit its own detailed, specialty-specific feedback.
CY 2027 Conversion Factor
Once again, physicians are facing sizeable reductions in Medicare payments despite continued increases in practice costs and ongoing inflation. This ongoing instability makes it increasingly difficult for practices to recruit and retain staff, invest in new technologies, and maintain beneficiary access to care. We recognize that CMS cannot reform the Medicare physician payment system in a way that appropriately accounts for rising inflation, but it can and should avoid policies that further exacerbate longstanding structural problems.
Click here to view the full Alliance of Specialty Medicine Comments on CY 2027 Medicare OPPS and ASC Proposed Rule (CMS-1850-P)
