The ACC submitted formal written comments to the Centers for Medicare and Medicaid Services (CMS) on the 2027 Medicare Physician Fee Schedule (PFS) proposed rule on Sept. 10. Notable topics covered in the College's letter include:

Ambulatory Specialty Model (ASM):

• Although the College agrees with the goals of improving heart failure (HF) care and reducing avoidable costs, the current ASM structure needs reconsideration and modification. The ACC stressed the importance of incorporating our guideline-directed medical therapy recommendations into the model as well as the member feedback which included significant uncertainty and low confidence to control costs from external clinicians and providers, submit the mandated quality data at the individual level through electronic health records (EHRs), and have access to timely and actionable patient-level claims data needed to be successful in the ASM program.
• The College strongly urges CMS to reconsider the current structure, including individual attribution framework, limited data transparency and the award and penalty methodology. The College further recommends that at least the first year of the model be designated as a no-risk educational and testing period to allow participants to better understand program requirements and performance expectations. Implementing these changes would necessitate postponing the current Jan. 1, 2027 start date.

Specific Code Valuations:

• Left Atrial Appendage Closure (33340): The ACC argues against another cut to the service of approximately 10%, disregarding RUC recommendation to maintain its current value.
• New Tricuspid Valve Replace and Repair: The ACC argues against a more than 28% cut to the RUC-recommended values for the new codes.
• Drug Coated Balloon Angioplasty: The ACC argues against a 19.5% cut to the new code which would value it lower than standard balloon angioplasty.
• Coronary IVUS: The ACC argues against the 20% and 25% cuts to the RUC-recommended values of these resurveyed services.

G2211:

• The ACC offers alternatives to the proposal to replace code G2211 with two modifiers that would add 16% to eligible billed services for non-Accountable Care Organization (ACO) participating physicians and 32% for ACO participants as additional payments issued via modifiers do not convey relative value units (RVUs) and could reduce physician compensation.

Efficiency Adjustment:

• The College reiterates its opposition to CMS imposing a regularly occurring reduction in procedure values based on perceived efficiency gains while there is no inflation-based increase for the physician fee schedule which hospital payment systems receive annually.
• The ACC also calls for any effected codes that had been reduced by resurvey during the 5-year look-back period of the policy to be exempt from the efficiency adjustment.

E/M With -25 Modifier Global Periods:

• The College urges CMS not to implement a proposed policy that would reduce E/M procedures billed with the -25 modifier on the same day as a 0-, 10- or 90-day global procedure by 50%.

Practice Expense Methodology:

• The ACC urges CMS to delay significant changes to the calculation of indirect practice expense until they present specialty and code level effects of the changes.

Quality Payment Program (QPP)/Medicare Shared Savings Program (MSSP):

• The ACC urges CMS to slow the transition away from traditional Merit-Based Incentive Payment System (MIPS) until MIPS Value Pathways (MVPs) are fully tested and widely adopted. While supporting the long-term move to specialty-focused reporting, the College emphasized that clinicians should not be forced into MVPs before the pathways are operationally ready.
• The ACC called for a larger and more meaningful role for cardiologists in Medicare ACOs. In comments on the MSSP Specialist Request for Information, ACC highlighted the need for specialist-specific incentives, performance measures, and accountability approaches that reflect the care specialists actually influence.
• Continued refinements of the Heart Disease MVP are needed before it becomes the primary reporting pathway for cardiovascular clinicians. Key recommendations included expanding specialty-relevant measures and improving alignment between quality and cost measurement.
• While digital quality measurement is taking priority, the College stressed that interoperability infrastructure and specialty registry integration must mature before clinicians are required to report through Fast Healthcare Interoperability Resources (FHIR)-based measures.
• CMS will need to focus prior authorization reform on reducing burden rather than creating new reporting requirements. The College encouraged gradual implementation of electronic prior authorization measures and protections for clinicians when payer or technology limitations exist.
• The ACC raised concerns that proposed changes to Advanced Alternative Payment Model (APM) participation policies could increase complexity for physicians who practice across multiple organizations. The College urged CMS to better understand the impact on specialists before finalizing the policy.

Health IT:

• The ACC supports CMS's proposal to define certain AI-enabled clinical software as "Software as a Medical Service (SaMS)" and establish a clearer framework for its use in health care. The College emphasized that these tools should support, not replace, physician judgment, and recommends strong standards for transparency, evidence, oversight, interoperability and physician involvement in implementation.
• The ACC responded to a CMS request for information on Duplicate Laboratory Testing and Imaging Interoperability and urges CMS to reduce unnecessary duplicate testing by improving interoperability and access to prior laboratory and imaging results, while recognizing that repeat tests are often clinically necessary or occur because existing data cannot be accessed or used effectively at the point of care. The College recommends preserving physician judgement, ensuring access to diagnostic quality images and associated data, strengthening standards and testing for health information exchange, and avoiding payment penalties when repeat testing results from interoperability failures rather than "inappropriate" utilization.

In addition to submitting formal written comments, the ACC, along with the Society for Cardiovascular Angiography and Interventions and the Heart Rhythm Society, met with a group of CMS representatives to discuss proposed reductions to the RUC-recommended values of several cardiovascular procedures. The meeting specifically addressed the proposed reductions to left atrial appendage closure, and newly created procedures for tricuspid valve replacement and repair and drug-coated balloon angioplasty. The meeting was a productive forum to present our rationales supporting the RUC valuations and address questions from CMS. We are hopeful that this dialogue, along with our written comments, will encourage CMS to implement the RUC-recommended values in the final rule, expected to be released in early November. 

The ACC also continues to meet with the Center for Medicare and Medicaid Innovation (CMMI) and CMS officials to raise concerns about the ASM program and urge program modifications needed to improve HF care and reduce avoidable costs.

Learn more about the proposed rule with ACC's deep-dive and use ACC's proposed rule calculator to assess potential impacts to your practice.

Keywords: Centers for Medicare and Medicaid Services, U.S., Fee Schedules, Delivery of Health Care, ACC Advocacy