Comment on CMS-2026-2377-0002

Dear Centers for Medicare & Medicaid Services, I am writing on behalf of The Ohio State University Center for Integrative Health (OSU CIH) regarding the proposed changes in Shared Medical Appointment billing. We appreciate CMS's recognition of Shared Medical Appointments as an evidence-based care model that can improve chronic disease management, patient engagement, and access to lifestyle and behavioral interventions. While we strongly support establishing a national reimbursement pathway for SMAs, several aspects of the proposal may unintentionally undermine the financial sustainability, effectiveness, and accessibility of these programs. Shared Medical Appointments enable healthcare organizations to provide coordinated, interdisciplinary care to larger numbers of patients while maximizing limited clinical resources. However, the proposed restrictions on group size, session duration, multidisciplinary billing, and reimbursement valuation may create operational challenges that threaten the long-term viability of SMA programs. The proposed maximum group size of ten participants does not reflect the realities of SMA operations. Like many programs, OSU CIH experiences scheduling changes and patient no-shows that can substantially reduce actual attendance. Limiting enrollment to ten participants may result in groups that are too small to achieve the peer support, social connection, and shared learning that contribute to successful outcomes. In addition, many SMA programs rely on enrollment of 10 to 15 participants to offset staffing, facility, technology, and administrative costs. Greater flexibility in group size would better support program sustainability while allowing organizations to meet patient needs. The proposed 60-minute session requirement is also concerning. Effective SMAs frequently require 90 to 120 minutes to provide individualized medical assessment, patient education, behavior-change counseling, skill development, and meaningful peer interaction. Patients with multiple chronic conditions often require additional time for goal setting, lifestyle medicine education, and collaborative problem solving. Restricting sessions to 60 minutes could reduce care quality and limit the effectiveness of the SMA model. We encourage CMS to avoid limiting SMAs to conditions considered primarily modifiable through lifestyle change. Patients in integrative and lifestyle medicine settings commonly present with multiple chronic conditions, including chronic pain, cancer survivorship concerns, and autoimmune disorders. Restrictive eligibility criteria could create unnecessary administrative burden and exclude patient populations that have demonstrated benefit from group medical care. We are particularly concerned that the proposed valuation of GSMAS may not adequately reflect the resources required to deliver high-quality SMAs. These visits involve significant preparation, care coordination, documentation, facilitation, and clinical decision-making. In many cases, the effort required exceeds that of a typical Level 3 established patient visit. If reimbursement does not appropriately account for provider time and operational costs, healthcare organizations may be unable to sustain SMA programs despite their demonstrated value in improving outcomes and reducing healthcare utilization. Adequate reimbursement is essential to support broader adoption and continued investment in these care models. To support successful implementation of the GSMAS code, we respectfully recommend that CMS: - Allow flexibility in eligible conditions and avoid narrow disease-specific limitations. - Permit session durations consistent with evidence-based SMA models, including 90- to 120-minute formats. - Increase flexibility in group size to accommodate operational realities and support program sustainability. - Reevaluate reimbursement valuation to ensure it reflects the complexity and resources required for effective SMA delivery. We commend CMS for recognizing the value of Shared Medical Appointments and establishing a national reimbursement pathway for this important care model. However, the proposed restrictions may unintentionally reduce patient access, limit innovation, and jeopardize the financial sustainability of SMA programs. Greater flexibility in program design, reimbursement, and multidisciplinary participation will better support healthcare organizations in delivering high-quality, patient-centered care while advancing CMS's goals of improving outcomes and reducing the burden of chronic disease. Thank you for your consideration of these comments. Sincerely, Colleen Lowry Business Operations Manager