CMS issued the proposed rule CMS-1832-P on July 16, 2025, titled Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program.
On September 11, 2025, ASIPP submitted a comment letter advocating for the following:
- Elimination of proposed efficiency adjustment, which is inappropriate, and efficiency is rather decreasing than increasing.
- Due to escalating costs, practice expense cuts applicable to independent physicians need to be addressed.
- Ambulatory Specialty Model (ASM) appears to be without evidence and inappropriate, putting independent physicians at high risk for survival; consequently, this should be eliminated or conducted voluntary trial for five years.
- Telehealth services must be made permanent.
Enclosed are ASIPP’s detailed comment letter, Chairman Comer’s recent letter to CMS and OMB, and 3 published articles addressing this issue.
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- Manchikanti L, et al. Physician payment reform in interventional pain management: Balancing cost, quality, access and survival of independent practices. Pain Physician 2025; in press.
- Manchikanti L, et al. Non-partisan proposal for reforming physician payment system and preserving telehealth services. Pain Physician 2025; 28:E329-E335.
- Manchikanti L, et al. Escalating growth of spending on Medicare Advantage (MA) plans: Save Medicare from insolvency and balance the budget. Pain Physician 2025; in press.