Comment on CMS-2026-2377-0002

Re: CMS-2027 Medicare Physician Fee Schedule Proposed Rule To Whom It May Concern: I appreciate the opportunity to comment on the proposed Calendar Year 2027 Medicare Physician Fee Schedule on behalf of The Hirsh Center for Arthritis and Sports Medicine, an independent rheumatology practice in Florida that cares for thousands of patients with complex autoimmune diseases. I strongly urge CMS to reconsider several provisions of the proposed rule because, taken together, they will reduce patient access to care, increase administrative burden and place additional financial pressure on community physician practices. While each proposal deserves individual consideration, it is their cumulative effect that is most concerning. First, the proposed reduction in the Medicare physician conversion factor continues a pattern of declining physician reimbursement despite rising operating costs, workforce shortages and increasing administrative requirements. Physician practices cannot continue absorbing annual payment reductions while simultaneously being expected to expand access and improve quality. Second, I am deeply concerned by the proposal to pay the highest-valued service at 100% while reducing payment for additional separately payable services performed during the same patient encounter to 50%. This proposal creates a financial disincentive for physicians to deliver comprehensive, medically appropriate care during a single visit. In rheumatology, patients frequently require a comprehensive evaluation followed by a medically necessary office-based procedure on the same day. Examples include joint aspirations, therapeutic injections, ultrasound-guided procedures and other interventions that help patients avoid additional appointments, unnecessary travel and delays in treatment. Patients should never be required to return for a second visit when appropriate care can safely and effectively be delivered during the first encounter. Many of our patients are elderly, disabled or immunocompromised. They often travel long distances, rely on family members for transportation or have limited mobility. Requiring additional visits because payment policy discourages same-day care places unnecessary burdens on the very patients CMS seeks to serve. I am also concerned about proposals that further increase administrative complexity, including changes affecting Advanced Alternative Payment Models, continued transition to MIPS Value Pathways and additional restrictions on Remote Physiologic Monitoring and Remote Therapeutic Monitoring. Physician practices continue to devote significant resources to compliance rather than patient care. Although this rule is specific to Medicare, its influence extends well beyond the Medicare program. Commercial insurers frequently use the Medicare Physician Fee Schedule as the foundation for payment methodologies, coding policies and administrative requirements. As a result, these proposals have the potential to affect patients throughout the healthcare system—not only Medicare beneficiaries. CMS has consistently stated its commitment to improving access to care, reducing unnecessary administrative burden and supporting high-value care. Several provisions within this proposed rule move in the opposite direction. I respectfully urge CMS to: * Withdraw the proposal to reduce payment for additional separately payable services performed during the same patient encounter. * Reconsider the reduction in physician payment under the conversion factor. * Simplify, rather than expand, administrative requirements. * Continue supporting policies that allow physicians to provide comprehensive, medically appropriate care during a single patient visit. * Consider alternative approaches to achieving budget neutrality, including reducing excess payments within Medicare Advantage and evaluating opportunities to reduce or reform facility fee payments where appropriate. The future of American healthcare depends on preserving patient access to community physician practices. Payment policy should encourage timely, coordinated and efficient care—not create financial incentives that delay treatment or fragment the patient experience. Thank you for considering these comments. Respectfully, Meredith F. Hirsh, MBA, FACMPE Chief Executive Officer The Hirsh Center for Arthritis and Sports Medicine