Comment on CMS-2026-2377-0002

The proposed CMS-1848-P creates significant concerns for specialty providers, including podiatry practices and ambulatory surgery centers that already operate under increasing financial and regulatory pressures. Reductions in reimbursement, combined with rising costs for staffing, supplies, equipment, and compliance requirements, threaten the ability of independent surgical facilities to remain financially viable. Ambulatory surgery centers provide efficient, cost-effective care while helping reduce the burden on hospital systems. However, continued payment cuts and increased administrative demands risk limiting access to these services, particularly for patients in rural and underserved areas. Specialty practices such as podiatry are especially vulnerable because many procedures require specialized equipment, trained staff, and significant overhead expenses that are not adequately reflected when reimbursement is reduced. These proposed changes ultimately do not just impact providers—they impact patients. Lower reimbursement threatens provider participation, increases delays in care, and may force more procedures back into higher-cost hospital settings. CMS should consider the real-world financial impact on independent practices and surgery centers and work with providers to develop policies that preserve patient access, encourage cost-effective care, and support the sustainability of high-quality specialty services.