Comment on CMS-2026-1256-0002

National Alliance of Virtual Physicians Statement on CMS FY 2027 IPPS Proposed Rule and Physician-Led Innovation The National Alliance of Virtual Physicians (NAVP), founded in 2026, supports CMS's decision to seek stakeholder input regarding the participation of physician-owned hospitals in the Transforming Episode Accountability Model (TEAM) and welcomes the broader conversation about the role of physician-led organizations in advancing value-based care. NAVP was established to advance physician leadership, expand patient access, promote responsible innovation, improve quality, and ensure that physicians have a meaningful voice in shaping the future of healthcare delivery. As healthcare continues to evolve through new technologies, new care models, and increasing patient demand for access, we believe policies should encourage innovation while maintaining accountability for outcomes. We view CMS's request for information as an important opportunity to evaluate physician-led models based on measurable performance rather than organizational structure alone. Across healthcare, physician-led organizations have often faced regulatory barriers that limit their ability to grow, innovate, and compete. At the same time, patients increasingly face challenges related to access, affordability, workforce shortages, and consolidation within healthcare markets. These challenges require thoughtful solutions and a willingness to evaluate new and existing care models on their ability to deliver results. The Transforming Episode Accountability Model is built upon principles that NAVP strongly supports: accountability for quality, improved care coordination, responsible stewardship of healthcare resources, and better outcomes for patients. Organizations willing to accept those responsibilities should have the opportunity to demonstrate their value. NAVP believes healthcare policy should encourage competition, innovation, and physician leadership while maintaining strong safeguards for patients. We support CMS's efforts to examine whether qualified physician-led hospitals should be permitted to voluntarily participate in TEAM and encourage CMS to evaluate such participation through the lens of patient outcomes, quality metrics, transparency, beneficiary choice, and program integrity. As an organization representing physicians who practice in increasingly innovative and technology-enabled environments, NAVP recognizes that many of the barriers facing physician-led hospitals mirror those facing virtual care. In both cases, policy discussions should focus less on assumptions about care delivery models and more on measurable outcomes for patients. Patients benefit when physicians are empowered to innovate, compete, and lead. They benefit when high-quality care models are allowed to demonstrate their effectiveness. They benefit when policymakers prioritize access, affordability, quality, and accountability over institutional preferences. NAVP appreciates CMS's willingness to revisit these important questions and encourages continued exploration of policies that support physician-led innovation, strengthen patient choice, and improve access to high-quality care across the United States. Innovation should be encouraged. Outcomes should be measured. Patients should come first.