Requesting support to CMS and Congressional Members to Revise Proposed Physician Payment Rule to Separate the Cuts Applied for Hospital-Based Physicians from Independent Physicians

Requesting support to CMS and Congressional Members to Revise Proposed Physician Payment Rule to Separate the Cuts Applied for Hospital-Based Physicians from Independent Physicians

 

ASIPP is advocating strongly on behalf of interventional pain physicians, sending letters to Congress urging revisions to the proposed 2025 Physician Payment Rule from the Centers for Medicare & Medicaid Services (CMS). While ASIPP supports CMS’s goals of reducing waste, improving quality, and strengthening chronic disease management, the current proposal would have devastating consequences for interventional pain practices. These sweeping cuts risk accelerating healthcare consolidation, reducing patient access to pain specialists, and worsening physician burnout, at a time when practice costs are soaring, staff wages are rising, and reimbursement rates continue to fall.

Since 2001, interventional pain physicians have experienced some of the steepest cuts across all specialties, 41% through 2025, projected to reach 45% with the new rule. Even with modest office-based payment relief projected for 2026, the cumulative losses remain unsustainable.

In addition, CMS is introducing an Ambulatory Specialty Model (ASM) that will begin a trial phase in select states starting January 2027 and continue for five years through December 31, 2031.

This pilot will focus on two chronic conditions, low back pain and heart failure, with the following objectives:

1. Prevent the worsening of chronic conditions
2. Identify risks and early signs of chronic conditions
3. Improve patient experience
4. Reduce unnecessary procedures and surgeries

The specialties included are interventional pain management, anesthesiology, neurosurgery, orthopedic surgery, and physical medicine and rehabilitation. During the first payment year, adjustments will range from -9% to +9%, with all participants subject to this risk. Participation is mandatory, not optional.

However, there is no established or evidence-based guidance for this model, which significantly increases the risk for pain specialists. Pain specialists do not manage acute pain and have no control over many of the associated costs, yet they would still be held accountable for overall patient spending. These payment adjustments may apply to all Medicare services.

ASIPP urges CMS to eliminate the ASM until appropriate criteria are established and the model’s effectiveness is demonstrated.

ASIPP is urging Congress to:

• Reverse the proposed 2.5% efficiency adjustment to work RVUs and stop the cycle of devastating cuts every three years.
• Promote equitable treatment of independent pain practices in practice expense allocations, especially for services provided in Ambulatory Surgery Centers.
• Ensure the permanent extension of telehealth access beyond 2025, critical for chronic pain patients in rural and underserved areas.
• Direct CMS to distinguish reimbursement reductions between hospital-employed and independent physicians, protecting small pain practices from disproportionate harm.
• Ask CMS to withdraw this provision pending the development of appropriate criteria and validation of the model’s effectiveness.

Without these revisions, independent interventional pain practices, already under audit pressure and burdened by prior authorization requirements, face an uncertain future. Preserving their viability is essential to maintain patient access to timely, high-quality pain care and to prevent further healthcare consolidation that continues to drive up costs by 200–300%.

SAMPLE LETTER TO SEND TO REPRESENTATIVES IN CONGRESS
ASIPP has prepared a sample letter you can personalize and send to your representatives in Congress.
Click here to find your congressional members 

By speaking out, you can help stop devastating cuts, protect independent interventional pain practices, and preserve patient access to high-quality pain care.
Please click here for a sample letter to send to your representatives.

SAMPLE LETTER TO SUBMIT COMMENTS TO CMS
For your convenience, we are enclosing a sample letter for you to customize and send to CMS to express concerns with the 2025 Medicare Physician Fee Schedule.
Please click here for a sample letter to submit your comments to CMS.

INFORMATION FOR SUBMITTING YOUR COMMENT LETTER
In commenting, please refer to file code CMS-1832-P. Comments must be received no later than 5 p.m. on September 12, 2025.
Click here to submit electronic comments on this regulation.

Please do not hesitate to contact us if you have any questions or would like additional information.

Thank you,

Laxmaiah Manchikanti, MD
Chairman of the Board and Chief Executive Officer, ASIPP and SIPMS
[email protected]

Mahendra Sanapati, MD
ASIPP President
[email protected]