ACOFP has submitted a detailed comment letter to the Centers for Medicare & Medicaid Services’ (CMS) on the Calendar Year (CY) 2026 Physician Fee Schedule (PFS)Proposed Rule (“Proposed Rule”). While ACOFP supports some of the provisions in the Proposed Rule, particularly those aimed at recognizing the value of primary care, others must go further in order to protect primary care physicians, especially rural physicians and those in solo and small practices. Specifically, CMS should finalize a sustainable annual update to the proposed conversion factor (CF) that will ensure the financial viability of osteopathic family physician practices past the current year.
Below are some of the details of the Proposed Rule that affect osteopathic family physicians. Many aspects of the Proposed Rule are key to ACOFP's advocacy priorities, especially preserving the family medicine model of care and improving outcomes and reducing costs through access to primary care.
Payment
- CY 2026 CF: CMS proposes two separate CFs in 2026 that are required by statute one for APM participants and one for non-APM participants. ACOFP supports the proposed increases (3.83% for APM and 3.62% for non-APM), but stresses the need for further financial support for physicians, especially osteopathic family physicians, due to increasing practice costs and stagnant reimbursements. ACOFP points out that osteopathic family physicians are essential to the nation’s public health system and play a critical role in providing care to Medicare beneficiaries. Despite their contributions to patient care and public health, osteopathic family physicians have been forced to contend with Medicare payments that do not cover the cost of providing care. ACOFP argues that current CFs are inadequate for covering inflation and rising practice expenses, particularly for solo, independent, and rural practices.
- Efficiency Adjustment: CMS proposes a 2.5% efficiency adjustment for 2026, which could benefit specialties like family medicine (due to more frequent billing of timed codes). However, ACOFP is concerned about the impact on Osteopathic Manipulative Treatment (OMT) services, which may face cuts in reimbursement despite being a cost-effective, high-value treatment. ACOFP advocates for the protection of OMT from these reductions.
- Redistribution of Facility and Non-facility Practice Expense (PE)Relative Value Units (RVUs): ACOFP supports the redistribution of practice expense RVUs from facility to non-facility settings to help independent practices, particularly small and solo osteopathic family medicine practices. However, ACOFP urges CMS to consider the potential negative impacts, such as reductions in reimbursement for commercial insurers and challenges for employed physicians in meeting productivity targets.
Telehealth Services
- Streamlining Telehealth: ACOFP's advocacy priorities include encouraging the appropriate use of telehealth. ACOFP supports CMS's proposal to streamline the 5-step review process for adding services to the Medicare Telehealth Services List, which could expand access to telehealth, particularly in underserved areas. However, ACOFP believes that telehealth should complement, not replace, in-person care and must be used to maintain the physician-patient relationship, particularly for chronic disease management.
- Direct Supervision via Telehealth: ACOFP supports CMS's proposal to allow direct supervision via real-time audio/video technology for certain services, which provides flexibility for teaching and patient care. ACOFP urges CMS to maintain this flexibility for teaching physicians, especially those in rural or underserved areas.
Enhanced Care Management
- Behavioral Health Integration Add-On Codes: ACOFP supports policies that increase access to primary care, such as including preventive services in the Advanced Primary Care Model (APCM) bundle and providing prospective payments to encourage broader adoption of advanced primary care management. ACOFP suggests creating additional policies to reward osteopathic family physicians for their role in preventing and managing chronic diseases.
Care Complexity Add-On Code
- G2211 Expansion: ACOFP supports CMS's proposal to allow expanded use of the G2211 code to ensure appropriate reimbursement for primary care services, which would improve the accuracy of service valuation.
Policies to Improve Care for Chronic Illness and Behavioral Health Needs
- Chronic Disease Management: ACOFP urges CMS to focus on improving payment policies for primary care to better support the prevention and management of chronic diseases. ACOFP calls for adjustments to address the financial pressures faced by primary care physicians, especially in rural and small practices, which are struggling due to increasing operational costs and administrative burdens.
- Medically-Tailored Meals and Digital Therapeutics: ACOFP supports creating separate codes for medically-tailored meals and FDA-cleared digital therapeutics to improve chronic disease management. ACOFP emphasizes the need for evidence-based products and integration into care plans.
- Annual Wellness Visit (AWV) Improvements: ACOFP supports CMS’s efforts to increase AWV uptake and recommends designating components of the AWV as optional add-on codes, which would reduce administrative burden and improve efficiency, particularly in independent practices.
Medicare Shared Savings Program
- Primary Care Definition Updates: ACOFP supports the updated definition of primary care services in the Shared Savings Program but opposes the removal of the Social Determinants of Health (SDOH) code (G0136). ACOFP advocates for including more SDOH-related codes to reflect holistic, whole-person care, which is central to osteopathic family medicine.
For more details on ACOFP's positions, read our full response and explore all of the comment letters we've submitted this year. The final rule is expected to be released in November.
