Supporting the Physiatrist, Strengthening the Specialty

On September 14, your Academy submitted extensive comments to the Centers for Medicare & Medicaid Services (CMS) regarding the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule. The Academy recommended changes to several proposed policies which could negatively impact payment for PM&R physicians. 

Of note, AAPM&R opposed CMS’s proposal to cut payments for same day care. Under this proposal, when an office/outpatient evaluation and management (E/M) service is provided on the same day as procedure, payment for the lower cost service would be paid at 50%. Recognizing the devastating impact of this proposal, AAPM&R has been advocating on this issue since the proposed rule was released. Further, AAPM&R launched a grassroots campaign supporting comment letters to CMS on this and other issues in the rule. Thank you to the PM&R physicians who submitted comments via our Member Action Center campaign! 

This was a robust proposed rule, with many other proposals relevant to PM&R. Additional highlights from the Academy’s comment letter include: 

• AAPM&R echoed concerns raised in past rule comments regarding the conversion factor and continuing instability of physician payment. Comments urge CMS to collaborate with Congress to secure meaningful long-term reforms that would achieve positive annual updates to physician payment reflective of the rising costs of providing high-quality patient care.  

• AAPM&R raised concerns about CMS’s proposal to convert the E/M visit complexity add on code, G2211, into a modifier (MOD1). We recommended CMS delay implementation in order to study the impact of this change on physicians who are subject to RVU-based reimbursement. 

• AAPM&R urged the CMS Innovation Center to designate 2027 and 2028, the first two years of the Ambulatory Specialty Model, as upside-risk-only years with no penalties. This would allow CMS to refine the model while giving participants sufficient time to prepare for successful participation. 

• AAPM&R provided feedback on several proposals related to the Quality Payment Program (QPP), expressing continued concern with CMS's proposal to require mandatory participation in MIPS Value Pathways (MVPs) beginning in 2029. The Academy noted that important measurement gaps remain for PM&R physicians, limiting the ability of current quality programs to fully capture the value and outcomes of rehabilitation care. AAPM&R urged CMS to maintain voluntary MVP participation and continue working with specialty societies to expand clinically relevant, patient-centered quality measures. 

The Academy will continue working with CMS, Congress, and other stakeholders to advance policies that strengthen physician payment, protect access to rehabilitation services, and recognize the value PM&R physicians provide to patients. AAPM&R appreciates the engagement of members who contributed to these advocacy efforts and will provide updates as CMS moves toward issuing the final rule in early November. Members with questions can contact us at healthpolicy@aapmr.org.  

On September 14, your Academy submitted extensive comments to the Centers for Medicare & Medicaid Services (CMS) regarding the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule. The Academy recommended changes to several proposed policies which could negatively impact payment for PM&R physicians. 

Of note, AAPM&R opposed CMS’s proposal to cut payments for same day care. Under this proposal, when an office/outpatient evaluation and management (E/M) service is provided on the same day as procedure, payment for the lower cost service would be paid at 50%. Recognizing the devastating impact of this proposal, AAPM&R has been advocating on this issue since the proposed rule was released. Further, AAPM&R launched a grassroots campaign supporting comment letters to CMS on this and other issues in the rule. Thank you to the PM&R physicians who submitted comments via our Member Action Center campaign! 

This was a robust proposed rule, with many other proposals relevant to PM&R. Additional highlights from the Academy’s comment letter include: 

• AAPM&R echoed concerns raised in past rule comments regarding the conversion factor and continuing instability of physician payment. Comments urge CMS to collaborate with Congress to secure meaningful long-term reforms that would achieve positive annual updates to physician payment reflective of the rising costs of providing high-quality patient care.  

• AAPM&R raised concerns about CMS’s proposal to convert the E/M visit complexity add on code, G2211, into a modifier (MOD1). We recommended CMS delay implementation in order to study the impact of this change on physicians who are subject to RVU-based reimbursement. 

• AAPM&R urged the CMS Innovation Center to designate 2027 and 2028, the first two years of the Ambulatory Specialty Model, as upside-risk-only years with no penalties. This would allow CMS to refine the model while giving participants sufficient time to prepare for successful participation. 

• AAPM&R provided feedback on several proposals related to the Quality Payment Program (QPP), expressing continued concern with CMS's proposal to require mandatory participation in MIPS Value Pathways (MVPs) beginning in 2029. The Academy noted that important measurement gaps remain for PM&R physicians, limiting the ability of current quality programs to fully capture the value and outcomes of rehabilitation care. AAPM&R urged CMS to maintain voluntary MVP participation and continue working with specialty societies to expand clinically relevant, patient-centered quality measures. 

The Academy will continue working with CMS, Congress, and other stakeholders to advance policies that strengthen physician payment, protect access to rehabilitation services, and recognize the value PM&R physicians provide to patients. AAPM&R appreciates the engagement of members who contributed to these advocacy efforts and will provide updates as CMS moves toward issuing the final rule in early November. Members with questions can contact us at healthpolicy@aapmr.org.