Envision Advocates for Sustainable Medicare Reimbursement and Continued Access to High-Quality Care

Envision submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule. The comments focused on the policies that most directly affect clinicians, the patients and communities they serve and the long-term stability of the healthcare system.

Every day, clinicians navigate the challenges of delivering care in the complex and flawed U.S. healthcare system. They face stagnant reimbursement amid historic inflation, increasing workforce pressures and greater administrative and regulatory burdens.

Envision is committed to safeguarding the future of medicine for clinicians and patients. We believe that Medicare payment policies must reflect the realities of providing care today while keeping pace with the evolving healthcare landscape. Envision’s PFS comments specifically addressed the following:

Reimbursement Provisions

• Opposing the Conversion Factor reduction and any cut to Medicare reimbursement for the care clinicians provide. This is particularly concerning given the continued financial pressures clinicians face and the risk that unsustainable reimbursement could limit patients’ access to care.
• Encouraging CMS to refine its site-of-service payment differential policy so independent, facility-based clinicians do not have to deal with disproportionate reductions to reimbursement for the lifesaving care they provide.
• Supporting continued progress on innovations in interoperability and data sharing to reduce duplicative testing, improve access to clinical information and ease administrative burdens for clinicians.

Quality Provisions

• Encouraging CMS to preserve hospital-based reporting pathways while pursuing the MIPS Value Pathways and other quality programs. This prioritizes actionable programs that produce meaningful quality care measures while reducing administrative burdens on clinicians.
• Supporting the thoughtful evaluation of future digital reporting requirements and the transition to Fast Health Care Interoperability Resources (FHIR)-Based Digital Reporting, while recognizing the operational investment required to implement major reporting transitions.

We will continue working with CMS and industry stakeholders to help them understand the impact of these policies on clinicians and their patients and advocate for solutions that better reflect the value, complexity and cost of delivering high-quality care.

See the full comment letter Envision submitted to CMS here.