Comment on CMS-2026-2377-0002

ABC Coding Solutions, Inc. respectfully submits this executive summary in response to CMS’s Request for Information on the Current Procedural Terminology (CPT) coding system. Our full comment letter is attached. We appreciate CMS’s thoughtful questions regarding exclusive reliance on a privately owned coding system, the relationship between code development and medical necessity, alternatives to CPT, the objectivity of existing processes, and the potential for competition. Our comments are offered with professional courtesy and a clear, nonpartisan commitment to improving access to care, lowering total costs for patients and taxpayers, expanding insurance options for effective lower-cost services, and strengthening program integrity against waste and fraud—priorities that benefit the American people regardless of administration or political party. CPT has served an important role in standardizing physician procedure reporting. However, exclusive practical reliance on a physician-centered code set leaves many preventive, integrative, nursing, nutritional, behavioral, rehabilitative, and other non-pharmacologic services delivered by licensed professionals without accurate codes. Services that cannot be precisely coded become invisible to claims systems: they cannot be consistently reimbursed, studied, incorporated into benefit design, evaluated for medical necessity, or included in value-based models. This restricts patient access—especially in rural and underserved communities—and steers care toward higher-cost physician visits, facility procedures, diagnostics, and pharmaceuticals simply because those services are already visible and processable. The result is higher insurance costs and total spending without corresponding gains in outcomes. We urge CMS and HHS to end exclusive reliance on CPT as the practical gateway for professional services and to establish a competitive, federally supervised pathway for qualified alternative code sets, including ABC Codes, to supplement CPT and HCPCS. ABC Codes were designed to describe precisely these under-represented services while identifying practitioner type and state jurisdiction, supporting scope-of-practice compliance and outcomes analysis. Key Recommendations Permit approved alternative code sets to supplement (not replace) CPT and HCPCS. Conduct a 30-month demonstration allowing ABC Codes to be reported alongside CPT, HCPCS, and ICD-10 for selected preventive, integrative, nursing, nutritional, and non-pharmacologic services, with rigorous comparison to three years of historical claims data. Create an independent, multi-stakeholder coding-governance process under federal oversight, separate from payment valuation. Require transparent governance, conflict-of-interest disclosures, reasonable licensing, interoperability, clinical validity, and state scope-of-practice safeguards for any recognized code set. Maintain a clear distinction: the existence of a code enables accurate reporting and evidence generation; it does not automatically confer coverage or payment. These steps would expand access to appropriately licensed professionals, make lower-cost options visible and measurable, generate the claims data needed for evidence-based decisions, reduce administrative friction and fraud risk, and help ease pressure on insurance premiums and total Medicare spending. A health care system cannot evaluate, reward, or improve what it cannot identify. We request that CMS initiate the recommended demonstration and pathway for supplemental coding. Our full letter provides detailed responses to each of CMS’s questions, supporting analysis, and evaluation measures. We stand ready to assist CMS in any way that advances accurate reporting, patient access, and fiscal responsibility.