The commenter argues that CMS should require certified EHR vendors to support all CMS-approved quality reporting methodologies as a condition of certification. They contend that providers should not be penalized for technology limitations outside their control and suggest that CMS provide technical exemptions if a vendor cannot support a required reporting method.

The commenter supports the proposed 15% increase in work RVUs for labor management and delivery codes but argues that the overall valuation of maternity care remains undervalued. They also oppose the creation of new HCPCS G-codes, citing concerns over administrative burden and reimbursement fragmentation across different payers.

Remo Medical Group, a virtual dementia specialty practice, strongly supports the creation of HCPCS codes GACP1 and GACP2 and their inclusion on the Medicare Telehealth Services List. They argue that these codes are necessary to compensate clinical staff for advance care planning and advocate for the retention of separate codes to ensure clear tracking of physician versus clinical staff time.

ABC Coding Solution, Inc. argues that the exclusive reliance on the privately owned CPT coding system limits access to non-pharmacologic and non-physician services by making them "invisible" to claims systems. They urge CMS to establish a federally supervised pathway for supplemental code sets, specifically proposing a 30-month demonstration for their own "ABC Codes" to improve data accuracy and healthcare costs.

The commenter, an administrator of an OB/GYN practice and certified coder, opposes the adoption of new G codes for maternity care. They argue that adding these codes would cause confusion for providers and patients, increase the burden of training and staffing, and complicate the claims process with payers.

The commenter opposes the proposed functional improvement measures for patients with various impairments because the methodology for calculating Predicted Moderate Clinical Improvement (P-MCI) is not publicly available or independently implementable. They argue that the current proposal creates a dependency on proprietary platforms (Limber Health or Patient360), which imposes financial and technical burdens on practices and prevents transparent auditing.

Birmingham Obstetrics & Gynecology, P.C. supports the adoption of new maternity care CPT codes for 2027 and opposes the creation of HCPCS G-codes that would preserve the old global billing structure. They argue that maintaining parallel coding systems would increase administrative burdens, cause confusion, and fail to accurately reflect contemporary individualized prenatal care.

Dr. Wirt Hines, a physician, opposes the proposed policy to reduce reimbursement for separately identifiable E/M services and procedures performed on the same day. The commenter argues that the policy will create financial incentives to separate these services, leading to increased patient travel burdens, higher administrative costs, and potential increases in overall Medicare spending.