The ACC submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on Sept. 12 after the agency issued proposed rules for the 2026 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) in July.

The College's comments on the Medicare PFS addressed several topics with the potential to impact the cardiovascular community, making the following recommendations:

• CMS should not finalize its proposal to create a site of service payment differential that reduces payment for "hospital-based" services due to unverified concern that payment for overhead in the hospital setting through the PFS could be redundant.
• CMS should not finalize its proposal to reduce nearly every service in the PFS – except for E/M services and similar time-based services – through an efficiency adjustment.
• The ACC acknowledges the proposed Ambulatory Specialty Model for heart failure and the complexity for treating these patients faced by specialists participating in an Alternative Payment Model; however, additional considerations regarding the participating physicians, patient attribution and other model elements should be addressed to make the program viable.
• The letter includes extensive comments regarding how CMS should assess and pay for Software as a Service.
• The agency's proposal for a large reduction to left atrial appendage occlusion services – compounded by other proposed structural changes to the PFS – warrants reconsideration while the ACC and other cardiovascular societies conduct a new survey of the code.

ACC's comment letter also addresses various other proposals, touching on telehealth policy, quality measures, the Quality Payment Program and more.

Regarding the Hospital OPPS proposed rule, the ACC focused its comments on large, programmatic changes as well as narrower payment adjustments that will impact specific services. Key highlights from the comment letter include the following:

• The ACC recommends a more cautious approach in sunsetting inpatient-only (IPO) list of services. The plan as outlined in the proposed rule appears too aggressive to accomplish without creating negative, unintended consequences.
• The planned liberalization of the process for adding services to the ambulatory surgery center (ASC) covered procedures list (CPL) creates opportunities for patients to receive care in locations of their choice, but safety and quality of care must be a priority.
• The addition of cardiac ablation services to the ASC CPL presents the opportunity for clinicians to provide these services with greater efficiency and flexibility for carefully selected patients.
• Large cuts for several imaging and diagnostic services – stress tests, amyloid imaging, etc. – should not be finalized after CMS proposed to dramatically change the groupings of services inside Ambulatory Payment Classifications. Those groupings should be reversed, and the agency should use its equitable adjustment authority to avoid harming important services.

The comment letter also covers cardiovascular rehabilitation supervision, hospital quality measures, radiopharmaceutical payment policy and other significant proposals.

In addition to submitting formal comments, ACC Advocacy staff and leaders have met with CMS concerning proposals in both rules. Final rules are expected in early November. Learn more about these proposals with ACC's Guide to the 2026 Medicare Proposed Rules and use ACC's proposed rule calculator to assess potential impacts to your practice.

Clinical Topics: Heart Failure and Cardiomyopathies, Acute Heart Failure

Keywords: Centers for Medicare and Medicaid Services, U.S., ACC Advocacy, Fee Schedules, Outpatients, Physicians, Ambulatory Surgical Procedures, Prospective Payment System, Heart Failure