Comment on CMS-2026-2377-0002

Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1848-P P.O. Box 8016 Baltimore, MD 21244-8016 Re: CMS-1848-P, Medicare Program; CY 2027 Payment Policies Under the Physician Fee Schedule (Docket CMS-2026-2377) Dear Administrator Oz: We write as the Big Five Coalition, the elected leadership of the medical societies of California, Texas, New York, Florida, and Pennsylvania, in strong opposition to the proposed CY 2027 reduction in the Medicare physician conversion factor. Together, our five states are home to more practicing physicians than any others in the country: over 400,000 physicians, nearly 40 percent of the entire U.S. physician workforce. We are elected by these physicians to advocate and formulate healthcare policy that promotes patient health and practice structures that effectively provide such care. This proposed cut is not a technical adjustment. It is the continuation of a policy failure that has now gone on for over three decades. Considering inflation, Medicare physician payment has collapsed 53 percent since the advent of the Resource-Based Relative Value Scale (RBRVS) in 1992, a decline without parallel anywhere else in American medicine, and one that no other sector of the economy would tolerate for a single year, let alone thirty. Physicians remain the only participant in the Medicare program with no statutory mechanism to keep pace with inflation. Physicians MUST be paid at an economically viable rate. Hospitals, skilled nursing facilities, and Medicare Advantage plans all receive built-in, predictable updates. Physicians do not. Every year, physicians are asked to treat more patients, absorb higher practice costs, and accept less. It is not defensible, particularly when placed next to CMS's own actions in the same rate-setting cycle. In April 2026, CMS finalized a 2.48 percent, $13 billion-plus payment increase for Medicare Advantage plans for CY 2027, revised upward from a proposal that began nearly flat. Medicare Advantage plans are not required to demonstrate that this additional spending lowers costs or improves outcomes for a single beneficiary. Physicians are being cut on a formula. Insurers are receiving a raise on a negotiation. CMS cannot credibly argue that the physician cut reflects fiscal restraint while simultaneously expanding payment to a program with no comparable accountability standard. The consequences of continuing this pattern are not hypothetical. Physicians facing unsustainable reimbursement are already limiting new Medicare patients, retiring earlier than planned, or leaving clinical practice altogether. This accelerates the physician shortage the country is already experiencing and will fall hardest on Medicare beneficiaries in rural and underserved communities who have the fewest alternatives.   We call on CMS to: 1. Withdraw the proposed CY 2027 conversion factor reduction and replace it with a positive update reflecting the Medicare Economic Index. 2. Establish a permanent, statutory link between the physician conversion factor and the Medicare Economic Index, ending the annual cycle of cuts and temporary congressional patches. 3. Eliminate the site-of-service payment differential, which pays more for identical care simply because it is billed by a hospital-owned outpatient department rather than a physician's office. The Congressional Budget Office estimates that expanding site-neutral payment across hospital outpatient departments, imaging, and drug administration would save Medicare more than 170 billion dollars over ten years, with no reduction in the care beneficiaries receive. This is a proven, scored source of federal savings that does not require cutting physician payment to achieve. Congress and CMS have had over three decades to correct this. Physicians have absorbed the cost of that inaction. Patients are about to absorb the consequences of a physician workforce CMS has spent more than thirty years underpaying. We urge CMS to reject this proposed rule and finally end the practice of financing the rest of the Medicare program on the backs of the people delivering the care. Respectfully submitted, Michelle A. Berger, MD Chair, Big Five Coalition & Texas Delegation to the AMA Albert Ray, MD Chair, California Delegation to the AMA Mark A. Dobbertien, DO Chair, Florida Delegation to the AMA Gregory L. Pinto, MD Chair, New York Delegation to the AMA Jill M. Owens, MD Chair, Pennsylvania Delegation to the AMA