September 16, 2025
On September 12, PALTmed submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule. PALTmed emphasized how CMS’ proposals could directly impact access to high-quality care for frail, older adults in nursing homes and other long-term care settings.
Key areas of concern highlighted in PALTmed’s letter include:
Conversion Factor Reductions: The proposed rates continue a troubling trend of flat or declining Medicare reimbursement, placing additional strain on PALTC clinicians, particularly those not participating in Advanced Alternative Payment Models (APMs).
Practice Expense (PE) Adjustments: CMS’ plan to reduce PE RVUs in facility settings, like skilled nursing facilities, does not reflect the real-world costs carried by PALTC clinicians. PALTmed strongly urged CMS to maintain equal PE values across nursing home settings to preserve access to care.
G2211 Add-On Code: While supporting its expansion to home and residence-based visits, PALTmed called for inclusion of nursing facility visits as well, recognizing the similar complexity and longitudinal nature of these services.
Telehealth Flexibilities: PALTmed endorsed CMS’ proposal to remove telehealth frequency limits for nursing facility subsequent visits and advocated for permanent extension of COVID-era waivers on geographic and originating site restrictions.
Quality Payment Program (QPP) Reforms: The letter urged CMS to reduce unnecessary regulatory burden under the Merit-based Payment System (MIPS), prioritize measures that are clinically relevant to PALTC, and provide timely performance feedback to physicians.
PALTmed also expressed support for CMS’ efforts to streamline telehealth policies and reform payment for skin substitutes, while urging the agency to ensure that reforms remain patient-centered and equitable.
PALTmed urged CMS to ensure that physician payment policies reflect the realities of PALTC practice, “Now is the time to invest in the clinician workforce, not reduce it. Ensuring access to high-quality care in nursing homes is essential not only for improving outcomes for some of Medicare’s most vulnerable beneficiaries, but also for strengthening the program’s financial sustainability. When skilled clinicians are available to care for this complex population, avoidable hospitalizations, emergency department visits, and costly complications are significantly reduced, resulting in substantial savings for Medicare. Providing adequate reimbursement is key to maintaining access to quality care for residents and ensuring stability within the PALTC workforce.”