Comment on CMS-2026-2377-0002

I represent one of the 5,800+ Rural Health Clinics (RHCs) across the country providing essential outpatient care to over 40 million rural Americans. I am writing to express disappointment with the Centers for Medicare and Medicaid Services (CMS) for not using their authority to further strengthen access to preventive care in the RHC setting via the CY2027 Medicare Physician Fee Schedule (MPFS) Proposed Rule. Specifically, CMS did not propose changes to the RHC medical visit definition that would allow Annual Wellness Visits (AWVs), other than Initial Preventive Physical Examinations (IPPEs), to qualify for same-day billing. The proposed rule also does not permit Registered Nurses (RNs) to furnish AWVs in RHCs, despite this flexibility being available in other care settings. CMS has previously stated their intention of establishing greater equity between RHC and Federally Qualified Health Center (FQHC) policy, especially pertaining to preventive health and payment policy. The above changes would achieve this goal and ensure greater access to primary care in rural areas. Please support RHCs by adding same-day billing flexibilities for AWVs as well as the ability for RNs to furnish these services in RHCs in the CY2027 MPFS Final Rule. Thank you.