SBA Advocacy Letter Echoes Provider Concerns Over CMS Physician Fee Schedule Proposal

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The Small Business Administration's Office of Advocacy (OA) on September 14, 2026, posted its comment letter to the Centers for Medicare and Medicaid Services (CMS) on the Calendar Year (CY) 2027 Physician Fee Schedule Proposed Rule. Congress established OA in 1976 to represent the views of small entities before federal agencies and Congress, and OA works to ensure that regulations do not unduly inhibit the ability of small entities to compete, innovate, or comply with federal laws. Small entities consist of small businesses, small governmental jurisdictions, and small organizations-the latter of which are generally defined as any not-for-profit enterprise which is independently owned and operated and is not dominant in its field.

In its letter, OA noted that the proposed rule presents a burdensome combination of lower baseline Medicare payments, changes to reimbursement methodologies, new billing requirements, and potential opportunities for primary-care and value-based care providers. In particular, OA stated that CMS' proposal to require billing practitioners to employ full-time remote patient monitoring (RPM)/remote therapeutic monitoring clinical staff would disproportionately harm small practices that do not have the patient volume necessary to justify hiring clinical monitoring staff and would make it economically unfeasible for small practices to continue offering these services. We cited similar concerns about CMS' proposal in our comments, stating that it could create an additional barrier for aging services providers that may not have sufficient staff or resources to continuously monitor data and respond to abnormal readings. As a result, this requirement could reduce providers' willingness and ability to offer RPM, even when it would be especially valuable in rural and under-resourced communities.

Additionally, OA noted how CMS' efforts to seek input on changing how primary care is valued and paid, including greater recognition of technology and the possibility of prospective primary-care payments through accountable care organizations and traditional fee for service Medicare, could eventually provide more predictable revenue for smaller providers. We expect CMS to issue a final rule in the coming month, as it is expected to take effect on January 1, 2027.