AAMC Comments on CY27 Physician Fee Schedule and Quality Payment Program Proposals

The AAMC submitted comments (PDF) to the Centers for Medicare & Medicaid Services (CMS) on Sept. 14 in response to the calendar year (CY) 2027 Physician Fee Schedule and Quality Payment Program (QPP) proposed rule [refer to Washington Highlights, July 17]. 

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 to reduce payment when a separately identifiable office/outpatient evaluation and management visit is furnished by the same physician or physician in the same practice on the same day as a global procedure, the AAMC advised the agency to address any resource overlap through the established misvalued code process on a code-specific basis instead of reducing payment for all such visits or global procedures. 

The AAMC supported proposals for Medicare to adopt new CPT codes for maternity care services and payment increases for psychiatric collaborative care services. Regarding remote services, the association’s letter urged the CMS to address any fraud and abuse concerns through oversight instead of creating employment-based restrictions. 

For the QPP, the AAMC recommended permanently maintaining traditional Merit-based Incentive Payment System (MIPS) reporting option and preserving voluntary participation of the MIPS Value Pathways, while working with stakeholders to identify longer term policy solutions to drive improvements in health care quality and access while reducing burden on clinicians.