Comment on CMS-2026-2377-0001

Harmeet MashianaOpposeIndividual
Summary: A physician from an independent private gastroenterology practice opposes the proposed CY 2027 Medicare Physician Fee Schedule due to concerns that low reimbursement rates and high regulatory costs threaten the sustainability of independent practices. The commenter urges CMS to provide payment updates that reflect inflation and practice costs while preserving physician independence and patient access.
I am writing as a physician in an independent private gastroenterology practice to express my concerns regarding the CY 2027 Medicare Physician Fee Schedule proposed rule. Independent physician practices remain the backbone of specialty care in many communities, providing timely access to high-quality, cost-effective gastrointestinal services. However, continued reductions in Medicare physician reimbursement, coupled with increasing regulatory requirements and rising practice expenses, threaten the financial sustainability of independent practices. Gastroenterology is a procedure-intensive specialty that requires significant investment in staff, equipment, endoscopy facilities, infection control, quality reporting, and patient safety initiatives. Reimbursement has not kept pace with inflation or the increasing costs of delivering care. Each year, private practices are expected to absorb higher labor costs, supply costs, technology investments, and compliance burdens while facing stagnant or reduced Medicare payment rates. As CMS finalizes the CY 2027 Physician Fee Schedule, I urge the agency to: Provide payment updates that reflect the true costs of physician practice and inflation. Minimize additional administrative and documentation burdens that divert physician time away from direct patient care. Ensure reimbursement policies adequately support office-based endoscopy and other procedures that provide high-value care while avoiding unnecessary hospital utilization. Recognize the critical role independent physician practices play in maintaining patient access, particularly in rural and underserved communities. Promote policies that preserve physician independence and prevent continued consolidation of medical practices into large health systems, which often increases overall healthcare spending without improving patient outcomes. Without meaningful payment reform, more independent gastroenterology practices will be forced to reduce services, limit Medicare participation, or sell to hospital systems or private equity-backed organizations. This trend ultimately reduces patient choice, decreases competition, and increases costs for the Medicare program. I appreciate CMS's efforts to improve the Medicare program and encourage the agency to adopt policies that support sustainable physician practices, preserve patient access to high-quality gastroenterology care, and ensure Medicare beneficiaries continue to receive timely, comprehensive digestive healthcare in their local communities. Thank you for the opportunity to comment on this proposed rule.

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