September 17, 2026- On September 14, Vizient® submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule, raising concerns with several proposals that would affect payment adequacy and care delivery while voicing support for policies that sustain access to telehealth.
In our comments, Vizient expressed concern that the proposed decline in both the qualifying and non-qualifying alternative payment model conversion factors, combined with continued growth in practice and supply costs, will leave providers facing even greater financial challenges. Vizient encouraged CMS to continue working with Congress to establish a stable, predictable and adequate payment update framework beyond CY 2027.
Vizient also called on CMS to withdraw a proposal cutting payment for certain evaluation and management (E/M) visits, warning that adjusting the existing policy could increase patient burden by encouraging appointments on different days. Similarly, Vizient recommended CMS withdraw proposed indirect practice expense changes due to concerns regarding reimbursement accuracy.
“Physician practices are absorbing rising costs while facing another year of declining payment, and several of these proposals would add to that pressure,” said Shoshana Krilow, senior vice president of public policy and government relations for Vizient. “We urge CMS to reconsider policies that reduce reimbursement for medically necessary services and to pursue approaches that support practice sustainability and patient access.”
On quality reporting, Vizient urged CMS to keep traditional Merit-based Incentive Payment System (MIPS) reporting in place rather than leaving MIPS Value Pathways (MVPs) as the only option for the 2029 performance period, cautioning that existing MVPs may not provide comprehensive, practical reporting pathways for all providers.
Separately, Vizient voiced support for CMS’s proposals to extend existing telehealth flexibilities and to add new services to the Medicare Telehealth Services List and urged the agency to work with Congress to make the COVID-19 public health emergency-related flexibilities permanent.
Learn more about Vizient’s advocacy and public policy efforts.