Consumers First Submits Comments On MPFS CY 2026

Families USA, on behalf of Consumers First and joined by 14 organizations provided comments on the Medicare Physician Fee Schedule (MPFS) for calendar year 2026 proposed rule. Consumers First offers these comments both to strengthen Medicare physician payment itself, and because the policy changes reflected in this comment letter represent an important step toward realigning the fundamental economic incentives in the health care system to meet the needs of all families, children, seniors, adults, and employers across the nation.

This letter expresses recommendations relating to and strong support for proposals across several key areas, including:

• Reducing the reliance on American Medical Association survey data when setting physician payment rates, including work RVUs and indirect practice expense RVUs and reforming payment setting methodologies to allocate more resources to independent and primary care practices.
• Expanding the scope of the Advanced Primary Care Management (APCM) service codes to include psychiatric collaboration care and behavioral health integration services.
• Introducing a new alternative payment model: Ambulatory Specialty Model (ASM) focused on improving cost and quality outcomes for physicians treating heart failure and low back pain.