Comment on CMS-2026-2377-0001

I am with Physician Anesthesia Services, a privately owned small physician and advanced practice provider anesthesia group based in Colorado, writing to express our concerns regarding the proposed 2027 anesthesia conversion factor, which is again slated to decrease. This proposal continues to raise significant concerns for anesthesia providers, who are already facing persistent workforce shortages, rising practice costs, increasing clinician burnout, and a steadily expanding Medicare beneficiary population. Despite these mounting pressures, the Medicare anesthesia conversion factor has remained in the $20 per unit range for nearly two decades, with no meaningful adjustment for inflation or changes in the cost of delivering care. The gap between the Medicare anesthesia conversion factor and commercially negotiated rates has widened substantially, with commercial reimbursement averaging approximately four times the Medicare rate. In Colorado, Medicaid reimbursement is also tied to the Medicare anesthesia conversion factor and is currently set at approximately 85% of the Medicare benchmark, resulting in an effective conversion factor of roughly $17 per unit. While benchmarking reimbursement to Medicare may be appropriate for many specialties, this methodology is unsustainable for anesthesia. The Medicare anesthesia conversion factor has historically lagged behind the actual cost of providing anesthesia services and perpetuates an already inadequate payment structure rather than establishing a reimbursement rate that reflects the resources required to provide safe, high-quality care. We are concerned that this continued trend of the Medicare anesthesia conversion factor will make it increasingly difficult for anesthesia providers to maintain access to care for Medicare and Medicaid beneficiaries, our historically most vulnerable patient population. We believe a complete assessment and overhaul is necessary to establish a conversion factor that more accurately reflects the cost and complexity of providing these essential services. We request a comparative analysis of reimbursement across physician specialties to evaluate how anesthesia payment rates compare with those of other procedural specialties, such as surgery. We urge Medicare to undertake such an evaluation before adopting a reimbursement methodology that continues to undervalue anesthesia services.