The Centers for Medicare & Medicaid Services (CMS) has finalized its largest regulation of the year: the 2026 Physician Fee Schedule (PFS). This annual rule sets the latest billing codes and payment rates for Medicare services and updates quality measures across Medicare programs.
It’s massive—2,750 pages—and draws thousands of public comments each year. These comments are the primary formal mechanism stakeholders have to influence policy before a regulation is finalized. This year, many of the policies C-TAC supported were adopted as proposed, and notably, CMS quoted four of C-TAC’s submitted comments verbatim in the final rule.
This kind of public acknowledgment signals that CMS not only heard C-TAC’s recommendations but felt they were important enough to explicitly reference. Even when suggestions are not immediately adopted, being quoted in the rule strengthens our positioning and increases the likelihood that CMS may incorporate these ideas in future policymaking.
Here are those four quoted comments:
1. Proposed Ambulatory Specialty Model
CMS proposed a new Center for Medicare and Medicaid Innovation (CMMI) heart failure model within the PFS. C-TAC recommended adding palliative care as a treatment option, drawing on experience working with the American Heart Association, which supports integrating palliative care for patients with advanced cardiovascular disease. CMS did not add palliative care to the model at this time, but on page 821 quoted our comment directly:
Another commenter recommended CMS adding palliative care as a treatment option for heart failure patients, noting alignment with the American Heart Association’s recommendation to integrate palliative care for patients with advanced cardiovascular disease.
CMS also asked for feedback on whether to include the Advance Care Plan (MIPS Q047) measure in the heart failure quality set. C-TAC supported its inclusion, explaining that it would drive meaningful improvements in patient experience and that cardiologists are often best positioned to lead advance care planning conversations.
Although CMS did not finalize the measure due to administrative burden concerns, they again quoted us verbatim on page 855:
A commenter supported the proposed inclusion of the MIPS Q047: Advance Care Plan measure because they believed that the measure would result in meaningful positive changes for patients which would justify any increased burden. The commenter also noted that the cardiologist is often the most appropriate provider to oversee advance care planning, since they can become the practical primary provider for patients with heart failure.
2. Ambulatory Palliative Care Patients’ Experience of Feeling Heard and Understood (MIPS 495)
C-TAC noted that this patient-experience measure is already included in multiple specialty sets—cardiology, clinical social work, family medicine, internal medicine, oncology/hematology, geriatrics, nephrology, neurology, and pulmonology—and recommended expanding it until it is part of every Medicare specialty measure set. The measure captures a core element of care: whether patients feel heard and understood by their clinicians. While CMS did not add it to new measure sets this year, they reiterated our recommendation on page 1969:
One of the commenters requested adding this measure to all specialty sets.
Given CMS’s steady expansion of this measure over recent years, there is still strong potential for broader adoption.
3. Proposal to Remove the Health Equity Adjustment
C-TAC did not support CMS’s proposal to eliminate the health equity adjustment. We questioned the rationale provided—specifically, why CMS would remove an adjustment that was originally added to strengthen incentives for high-quality care delivery and to advance equity. CMS ultimately finalized the removal but addressed our concerns directly on page 1351, quoting our comment:
Another commenter questioned why the health equity adjustment was added in the first place if it was duplicative of other adjustments.
In response to the comment that questioned why the health equity adjustment was added to begin with if it was duplicative of other adjustments, we note that, as discussed in the CY 2023 PFS final rule, our aim in finalizing the health equity adjustment was to encourage high ACO quality performance, reinforce ACOs’ transition to reporting all payer/all patient eCQMs/MIPS CQMs, and provide an incentive for ACOs to provide high quality care to all of the populations they serve. We also stated that, because every year a greater proportion of ACOs are making the switch to eCQMs, instituting a health equity adjustment for those ACOs making the switch to eCQMs will allow us to study the impacts and make refinements during subsequent rulemaking (87 FR 69839). Since we adopted thepatient’s health. health equity adjustment, we also note that we have added or extended other incentives to reinforce ACOs’ transition to reporting eCQMs/MIPS CQMs, including making the Complex Organization Adjustment available to ACOs that report eCQMs, extending the eCQM/MIPS CQM reporting incentive, and applying flat benchmarks to Medicare CQMs in their first two performance periods in MIPS.
CMS followed with a detailed explanation, reaffirming that the adjustment was intended to encourage strong ACO performance, support the transition to all-payer electronic clinical quality measure (eCQM) reporting, and improve care for underserved populations.
