NYHealth Comments on CMS’ Medicare Physician Fee Schedule Reform

NYHealth submitted the following comments in support of the Centers for Medicare and Medicaid Services' (CMS) proposed rule to reform the Medicare Physician Fee Schedule (PFS) by modernizing the methodologyfor valuing Relative Value Units(RVUs), the basic unit of measurement that determineshow much providers are paid for specificservices.

September 12, 2025

Dr. Mehmet Oz
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Subject: Public Comment on CY 2026 Medicare Physician Fee Schedule Proposed Rule
Docket ID: CMS-1832-P
Submitted via: regulations.gov

Re: Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2026

Dear Administrator Oz,

The New York Health Foundation (NYHealth) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services' (CMS) proposed rule regarding the Medicare Physician Fee Schedule (PFS) for Calendar Year 2026. Nearly 3.9 million New Yorkers[1] -almost 20% of the State's population-are enrolled in Medicare, making CMS policy decisions highly consequential for New Yorkers' health and wellbeing. Furthermore, Medicare payment policy often sets the pace for private payers.

NYHealth is a private, independent foundation dedicated to improving the health of all New Yorkers. We advance policies and initiatives that strengthen primary care services so New Yorkers can better prevent and manage chronic conditions. This work has provided us with in-depth knowledge of how high-quality primary care systems improve health care access and delivery.

We strongly support CMS's proposal to reform the Medicare Physician Fee Schedule (PFS) by modernizing the methodology for calculating Relative Value Units (RVUs), the basic unit of measurement that determines how much providers are paid for specific services.

Primary care has long been undervalued in the PFS, where high-value services such as chronic disease management and care coordination are often under-reimbursed or not reimbursed at all. Modernizing RVUs is essential to correcting decades of underinvestment, strengthening the financial foundation of primary care, and improving timely access for patients.

Our nation underinvests in primary care

Primary care is the cornerstone of a strong health care system. It is often a patient's first and most frequent point of contact with care and is one of the strongest predictors of better health outcomes. Research proves that accessible, high-quality primary care increases preventive care services-such as cancer screenings and flu vaccinations-and improves the management of chronic conditions like diabetes, hypertension, and asthma.^{[1], [2]} The evidence is clear: when primary care is available and accessible, people live longer, healthier lives.

Yet the nation's primary care system is falling short. In New York State, one in three residents live in a region with inadequate primary care access, with particularly severe shortages in rural communities and communities of color. More than 60% of rural counties in New York State are federally designated as Health Professional Shortage Areas for primary care, dental, and mental health.^[3] In predominantly Black neighborhoods, residents are 28 times more likely to live in census tracts with the most pronounced primary care shortages.^[4],[5]For many, this means traveling long distances, waiting weeks or months for an appointment, or forgoing routine care altogether.

Primary care saves money. When patients can't see their regular doctor when they need to, they get sicker and turn to hospitals or emergency rooms, where care is more expensive and more traumatic. The average cost of an ER visit is more than $1,200, compared with about $300 for a primary care visit.^[6]

Our health care system is fundamentally out of balance. In the United States, less than five cents of every health care dollar goes toward primary care-even though primary care providers handle one in three health care visits.^[7],[8] Increased investment in primary care will reverse decades of underfunding that have fueled provider burnout and workforce shortages.

This regulation is a critical step to correct the systemic undervaluation of primary care

The current valuation approach is flawed. It relies too heavily on limited data sources and fails to capture the full scope of services necessary to deliver high-quality primary care, resulting in inadequate payment.^[9]

CMS's proposed rule is an important step forward. By drawing on a broader range of data sources that better reflect the realities of primary care practice, CMS would modernize its valuation approach. This proposal aligns with recommendations from the National Academies of Sciences, Engineering, and Medicine's 2025 report, Improving Primary Care Valuation to Inform the Medicare Physician Fee Schedule, which notes that diversifying data sources-including electronic health record logs and other direct-observation data-will "enhance the accuracy, generalizability, and comprehensiveness of payment rate determinations."^[10]

The change will complement state-based efforts to increase investment in primary care

This proposed reform complements state-based efforts to rebalance their health care spending. At least 17 states have adopted policies to prioritize primary care spending,^[11] requiring payers to measure, report, and in many cases increase primary care spending.

New York State is taking a similar approach. Policymakers are weighing a proposal requiring health plans to direct 12.5% of total health care expenditures to primary care, and, if necessary, increase spending by 1% annually until the target is met.^[12]

State level policy changes have created momentum for rebalancing the health care system. By finalizing this proposed rule, CMS will reinforce and accelerate state efforts. Medicare has the ability to not only invest directly in primary care, but also signal to other payers, including Medicaid and private insurers, to follow suit.

Working together, federal action and state actions can strengthen the primary care system and make Americans healthy.

Conclusion

This reform is necessary and overdue; we strongly encourage CMS to finalize the proposed regulation. The proposal will help reverse the longstanding undervaluation of primary care.

We would be happy to answer questions or share additional insights from our primary care partners in New York State. For more information, please contact Program Officers Ali Foti ([email protected]) and Victoria Russo ([email protected]).

Sincerely,

David Sandman, Ph.D.
President and CEO
New York Health Foundation

References

[1] Levine DM, Landon BE, Linder JA. "Quality and Experience of Outpatient Care in the United States for Adults With or Without Primary Care," JAMA Internal Medicine 2019;179(3):363-372. https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2721037.

[2] Shi L, "The Impact of Primary Care: A Focused Review," Scientifica. 2012; 2012:432892. https://pmc.ncbi.nlm.nih.gov/articles/PMC3820521/.

[3] Office of the New York State Comptroller, "The Doctor is…Out. Shortages of Health Professionals in Rural Areas," https://www.osc.ny.gov/press/releases/2025/08/dinapoli-rural-counties-face-shortage-health-professionals, accessed August 2025.

[4] Brown E, Polsky D, Barbu C, Seymour J, Grande D. "Racial Disparities in Geographic Access to Primary Care in Philadelphia," Health Affairs 2016; 35(8). https://www.healthaffairs.org/doi/10.1377/hlthaff.2015.1612.

[5] "Predominantly Black neighborhoods" are census tracts where 80 percent of residents or more identify as African American.

[6] Agency for Health Care Research and Quality. "Information on the health status of Americans, health insurance coverage, and access, use, and cost of health services: Medical Expenditure Panel Survey (MEPS) Household Component (HC)," n.d., https://datatools.ahrq.gov/meps-hc/?tab=use-expenditures-and-population&dash=12, accessed February 2025.

[7] Patient-Centered Primary Care Collaborative, "Investing in Primary Care: A State-Level Analysis," July 2019.

https://www.pcpcc.org/sites/default/files/resources/pcmh_evidence_report_2019_0.pdf.

[8] National Academies of Sciences, Engineering, and Medicine, Implementing High-Quality Primary Care: Rebuilding the Foundation of Health Care, Washington, DC: The National Academies Press, May 2021. https://www.nationalacademies.org/our-work/implementing-high-quality-primary-care#sectionPublications.

[9] Ibid.

[10] National Academies of Sciences, Engineering, and Medicine. (2025). "Improving Primary Care Valuation Processes to Inform the Physician Fee Schedule." https://www.nationalacademies.org/our-work/improving-primary-care-valuation-decisions-for-the-physician-fee-schedule-by-the-center-for-medicare.

[11] Primary Care Development Corporation. (2024). State Trends Investment Update. https://www.pcdc.org/wp-content/uploads/2025-PCDC-Primary-Care-Update.pdf

[12] New York State Senate Bill 2025-S1634. (2005). https://www.nysenate.gov/legislation/bills/2025/S1634