The Honorable Mehmet C. Oz, MD, MBA
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
ATTN: CMS-1832-P
P.O. Box 8013 Baltimore, MD 21244-1850
Re: CMS-1832-P. Medicare and Medicaid Programs; CY 2026 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:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons nationwide, we thank you for your public service and determination to lead the Centers for Medicare & Medicaid Services (CMS). In your first term, you have a unique opportunity to do what your predecessors did not: fundamentally reexamine Medicare physician payment policy — particularly the Medicare Physician Fee Schedule (MPFS) — and treat it as the structural foundation of America’s health care ecosystem.
For decades, the MPFS has operated without meaningful reform, with annual updates that lag behind inflation and practice costs, while alternative payment models have proven largely unworkable. Since 2001, Medicare physician reimbursement has fallen 33 percent in real terms, even as practice overhead has risen nearly 50 percent.1 This chronic underpayment has destabilized the economics of independent practice, particularly for physicians whose payer mix is heavily Medicare-based and who lack commercial revenue to offset losses. Practices in rural, underserved, and lower-income communities are especially vulnerable, as are specialties that provide high-volume care to seniors. In these settings, reimbursement shortfalls leave few options beyond downsizing, closure, or sale to larger health systems. Hospitals, in turn, often acquire these practices and convert them into hospital outpatient departments (HOPDs) that bill Medicare at significantly higher rates for the same services. The result is a steady decline in competition and a shrinking independent workforce, with the share of U.S. physicians in private practice falling from about 60% in 2012 to less than 47% in 2022.2
Click here to view the full Neurosurgery responds to 2026 Medicare Physician Fee Schedule Proposed Rule
