LeadingAge comments on the CY2027 Physician Fee Schedule (CMS-1848-P) proposed rule submitted September 14, 2026, to the Centers for Medicare and Medicaid Services (CMS) respond to numerous proposals and requests for information proposed rule concerning payment policies under the physician fee schedule (PFS) and other changes to Part B payment and coverage policies.

We supported the agency’s proposal to equalize the rate for nursing facility visits that would ensure physicians are paid at the higher “community” rate for providing care to residents, regardless of whether the resident is classified as skilled or long-term care and CMS’ proposed transition timeline for Fast Healthcare Interoperability Resources-based quality reporting that would account for variations across programs.

However, we expressed concerns over CMS’ proposal to only allow payment for remote patient monitoring services when they are furnished by employees of the practice rather than third party contractors, as that could result in reduced access to care.

Additionally, we provided a number of recommendations relating to how CMS could reconfigure care management codes for longitudinal care management of senior living residents, including not making it contingent upon physical employment of or primary care practitioner ownership of the workforce providing these services.

With respect to palliative care, we emphasized the need for CMS to provide a sustainable billing pathway – in particular, the creation of a distinct code that identifies specialty palliative care and is paid for through a monthly bundle that sustains the non-billing members of the interdisciplinary team.

We also support changes to the advance care planning codes which would allow more members of the interdisciplinary team to bill their services.

Lastly, with respect to the Medicare Shared Savings Program Accountable Care Organizations (SSP ACOs), we provided recommendations that would help to expand partnerships between SSP ACOs and aging service providers including how residents could be aligned to the ACO and opportunities for aging services providers to receive financial incentives for participating in these ACOs.