PALTmed Submits Comments on Proposed 2027 Physician Fee Schedule

PALTmed submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2027 Medicare Physician Fee Schedule, outlining recommendations to support patient access and recognize the work of post-acute and long-term care (PALTC) clinicians.

Key recommendations included:

• Nursing facility payment equity: The comments supported CMS’ proposal to equalize practice expense payments for nursing facility visits billed under POS 31 and 32, regardless of a resident’s Medicare Part A coverage status.
• Stable physician payment: The comments called for permanent, annual inflation-based Medicare payment updates and cautioned against further practice expense reductions that overlook the costs nursing facility practices bear.
• Recognition of nursing facility primary care: The comments urged CMS to include nursing facility visits in proposed visit-complexity payment enhancements and ensure that broader primary care reforms include PALTC clinicians and their patients.
• Advance care planning and palliative care: The comments emphasized preserving clinician-led advance care planning and basing palliative care eligibility on patients’ serious-illness needs rather than a life-expectancy threshold.
• Appropriate quality reporting: The comments opposed ending traditional MIPS before a meaningful reporting pathway is available for nursing facility clinicians and called for performance comparisons that reflect the populations they serve.
• Telehealth and care coordination: Finally, the comments supported preserving telehealth access and improving clinical information sharing between nursing facilities, their clinicians, and accountable care organizations.

Throughout the letter, PALTmed emphasized that nursing facilities must be recognized as sites of primary care, rather than excluded from policies designed to strengthen it.