Comment on CMS-2026-2377-0002

Our practice is a privately owned orthopaedic practice with offices in three states. The proposed reductions including changes to the physician fee schedule conversion factor, practice expense methodology, and other reimbursement policies, raise significant concerns regarding the long-term sustainability of independent physician practices and healthcare organizations. I am writing to strongly oppose the proposed reimbursement reductions for total hip (CPT code 27130), total shoulder arthroplasty (CPT 23472) and knee arthroplasty (CPT code 27447) and the additional payment cuts in the CY 2027 Physician Fee Schedule. A 20% reduction in Medicare payment for these critical procedures — on top of last year’s 8% cut — is unsustainable. These cuts disproportionately harm independent physician practices that care for older, medically complex Medicare patients. They threaten our ability to continue providing timely, high-quality surgical and musculoskeletal care in the community. Total hip and knee replacements recently underwent a comprehensive physician-led valuation process. CMS should give significant weight to those findings rather than applying broad efficiency adjustments that do not reflect the real resources, time, and responsibility required for these complex cases. The proposed same-day E/M and procedure payment reductions (paying the highest service at 100% and cutting others to 50%), combined with the drop in the conversion factor, will further strain our practice. This will lead to physicians scheduling a separate appointment for procedures which will delay care and stress patients who now have to find an additional day off work and incur more expenses. This is not best for physicians or patients. Independent physicians are already facing increasing costs related to staffing, technology, supplies, regulatory compliance, administrative requirements, and the overall delivery of care. Some of these cuts directly relate to tariffs on supplies and loss of educational loans to educate qualified staff. Further, the unrestricted use of artificial intelligence to process pre-authorizations for procedures and testing as well as to deny claims has challenged our group’s ability to provide care and costs the group more time and money. This proposal disproportionately will harm independent physician practices again as we face further cuts to Medicare reimbursement. All this will accomplish is less access to care and penalizing physicians for coordinated care. Reduced reimbursement threatens the financial sustainability of independent orthopedic practices that provide timely access to musculoskeletal care. As practices consolidate or close, patients can expect longer wait times, diminished access to fellowship-trained arthroplasty surgeons, and reduced availability of elective joint replacement. I respectfully request that CMS reconsider these proposed reductions. Please consider alternative approaches that support sustainable reimbursement, reduce administrative burden, and protect access to quality healthcare. Thank you for considering this feedback as part of the rulemaking process. Sincerely, JoAnn Reis CEO