The North American Neuromodulation Society (NANS) has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed revisions to the 2026 Medicare Physician Fee Schedule (MPFS).
In its comments, several critical areas of the proposed rule are addressed, including:
- Conversion Factor Updates: Concerns about the growing payment gap between providers in advanced Alternative Payment Models and those in traditional Medicare.
- Efficiency Adjustment: Opposition to a proposed across-the-board cut to work RVUs based on assumed efficiencies not supported by data.
- Practice Expense Methodology: Feedback on site-of-service payment differentials and their potential to drive further practice consolidation.
- Ambulatory Specialty Model (ASM): Caution regarding mandatory participation and disproportionate burdens on small and independent practices.
- WISeR Program: Objections to labeling neuromodulation therapies as “wasteful” and highlighting risks of increased authorization barriers for patients in need.
Through these comments, NANS emphasizes the importance of maintaining patient access, supporting independent practices, and ensuring that Medicare policy reflects the real-world costs and clinical realities faced by physicians.