Medicare comment period nears end

Medicare’s public comment window on the 2027 Physician Fee Schedule closes Sept. 14, and more than 44,000 comments are already on file. Practices that want a say in what their rates look like on Jan. 1 have less than a week to write one.

The proposal, file code CMS-1848-P, runs 716 pages and was published in the Federal Register on July 16. Comments must be received by Sept. 14, 2026, not simply postmarked by then, and the Centers for Medicare & Medicaid Services will weigh them as they write the final rule.

The key aspect of the proposal is the conversion factor. The rule projects a 1.68% decrease for clinicians who are not qualifying participants in an advanced alternative payment model and a 1.19% decrease for those who are, a difference the Centers for Medicare & Medicaid Services explains in its fact sheet on the proposed rule.

They also propose to reduce payment for a separately identifiable office visit billed the same day as a procedure, rewrite how indirect practice expense is allocated, cap year-over-year practice expense swings at 5%, tighten who may furnish remote monitoring services and phase traditional MIPS into MIPS Value Pathways.

There are exactly three channels to file a comment: electronic, regular mail, and express or overnight mail. The simplest is electronic, where commenters can open docket CMS-2026-2377 on Regulations.gov and follow the submit a comment instructions.

Regular mail goes to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016. Express or overnight mail goes to the same attention line at Mail Stop C4-26-05, 7500 Security Blvd., Baltimore, MD 21244-1850.

Whichever route you pick, reference file code CMS-1848-P. The Centers for Medicare & Medicaid Services discourages duplicate submissions but says it will post acceptable comments from multiple unique commenters even when the content is identical or nearly identical.

Signing a specialty society’s form letter is not wasted effort, but it is also not the same as telling the agency something it does not already have. To make a comment count, name the section of the rule you are answering, then bring numbers only your practice has.

Everything you send is public, including any personally identifiable or confidential business information inside it. Strip patient details, cut anything you would not want a payer or a competitor reading and assume the comment is permanent.

If the rule is finalized as proposed, most of it takes effect Jan. 1, 2027. With the deadline approaching, practices should act quickly to ensure their voices are heard.