The AAMC submitted comments (PDF) to the Centers for Medicare & Medicaid Services (CMS) on Sept. 11 in response to the calendar year (CY) 2026 Physician Fee Schedule and Quality Payment Program (QPP) proposed rule [refer to Washington Highlights, July 18].
The CMS proposed two 2026 conversion factors: one for qualified participants (QPs) in alternative payment models at $33.59 and the other for non-QPs at $33.42, as required under the Medicare Access and CHIP Reauthorization Act (P.L. 114-10). The proposed conversion factors represent increases of 3.83% and 3.62%, respectively from 2025. A significant portion of the increase is due to the one-time 2.5% increase provided by Congress in the One Big Beautiful Bill Act (P.L. 119-21). Given the critical importance of patient access to health care services and the ongoing challenges faced by physicians, the AAMC encouraged the CMS to support stakeholders’ efforts urging Congress to pass legislation that would provide an annual inflation-based payment update based on the Medicare Economic Index.
In response to the proposed efficiency adjustment, a -2.5% cut to physician work valuation for all time-based services, and proposed change to practice expense to shift valuation of professional services provided in facilities to services provided in physician offices, the AAMC urged the CMS not to arbitrarily modify valuations of physician services based on one-size-fits-all adjustments. Instead, the association’s comments recommend the agency work with stakeholders on alternative policy options to achieve its goals to appropriately pay for services while improving patients’ access to care.
The AAMC also asked that the CMS extend the pandemic-era telehealth flexibilities where the agency has the authority to do so, for example, to allow virtual supervision of residents for telehealth services in all training locations, and further encouraged the CMS to work with Congress to make permanent, or at a minimum, to provide a two-year extension, of the remaining telehealth flexibilities.
In response to the newly proposed Ambulatory Specialty Model, the AAMC recommended that the CMS improve model design to ensure models support specialty engagement in value-based care delivery, including by making participation voluntary, allowing group practice participation and reporting, and better aligning model components to scoring and financial risk under the Merit-based Incentive Payment System.
Specific to the QPP, the AAMC’s comments recommended that the CMS work with stakeholders to identify longer term policy solutions that would bolster quality of care, improve access for all beneficiaries, improve patient outcomes, and reduce burden.