Consumers First Submits Comments On the 2027 Medicare Physician Fee Schedule (MPFS) Proposed Rule

Families USA, on behalf of Consumers First and joined by 28 organizations, provided comments on the Medicare Physician Fee Schedule (MPFS) for the calendar year 2027 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 includes recommendations across several key areas, including CMS’s proposals to:

• Improve the accuracy of Medicare physician payments by moving away from an overreliance on AMA survey data when calculating practice expenses.
• Explore ways through requests for information to improve primary care valuation and payment to primary care physicians.
• Formally sunset the Merit-Based Incentive Payment System (MIPS) and move participating providers into the MIPS Value Pathways as the primary quality reporting framework for providers not enrolled in Advanced Alternative Payment Models.