ACC comments on 2026 proposed fee schedule, outpatient system: 8 notes

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The American College of Cardiology has submitted comments to CMS asking for changes to the proposed rules for the 2026 Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System.

Here are eight things to know:

  1. The ACC suggested not finalizing a proposal to create a site of service payment differential that reduces payment for “hospital-based” services. 
  2. The organization expressed that CMS should not go through with its proposal to reduce nearly every service in the PFS, except for E/M services and similar time-based services through an efficiency adjustment.
  3. Additional considerations are needed for the proposed Ambulatory Specialty Model for heart failure regarding participating physicians, patient attribution and other model elements to make the model more viable.
  4. CMS’ proposal for a large reduction to left atrial appendage occlusion services, compounded by other proposed structural changes to the PFS, should be reconsidered, according to the letter from the ACC. 
  5. The ACC’s letter addresses other proposals, including on telehealth, quality measures and the Quality Payment Program.
  6. In terms of the Hospital OPPS proposed rules, the ACC recommends a more cautious approach in sunsetting inpatient-only list of services to avoid negative, unintended consequences. 
  7. The organization is in favor of adding services to the ASC-covered procedures list to allow patients to receive more care in the setting they choose, but emphasized the need to prioritize patient safety and quality of care. 
  8. The ACC said that the large proposed cuts for several imaging and diagnostic services should not be finalized.

Read the organization’s full letters on the Medicare PFS and Hospital OPPS proposed rules. 

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