Our comments, filed to the Centers for Medicare and Medicaid Services (CMS) on September 12, 2025, explain our opposition to proposed changes to practice expense methodology, our support for a proposal to permanently remove the Medicare telehealth frequency limitations for certain inpatient visits, nursing facility visits, and critical care consultation services; and we offer a big-picture perspective on the Medicare Shared Savings Program, with ideas for how this accountable care organization model could evolve to further engage and create opportunities for aging services providers. Read our comment letter below.