Draft Comments to Proposed CY 2027 Medicare Physician Fee Schedule

NAACOS is pleased to provide members with our draft comments to the CY 2027 Medicare Physician Fee Schedule proposed rule. The rule contains several key policy changes for ACOs and their aligned clinicians. We encourage members to use our comments in their own responses.

Comments on the proposed rule are due to CMS on September 14, 2026.

*Please note, the Word document draft has been updated with a draft response to the Specialty Care RFI (beginning on page 30).