AAPA Submits Comments on the 2026 Physician Fee Schedule Proposed Rule

September 11 ,2025

In response to the July release of the Centers for Medicare and Medicaid Services (CMS) 2026 Physician Fee Schedule proposed rule, AAPA has submitted comments calling on CMS to maintain transparency in PA service attribution, reduce administrative burdens, and improve patient access to care, among other priorities.

AAPA responds to the proposed physician fee schedule rule annually, supporting policies that are positive for PAs and patien, suggesting improvements to proposed policies, and expressing concern about policies that may unintentionally harm PAs and patients. Finalized policies frequently align with AAPA’s recommendations.

Key highlights from AAPA’s response include the following:

• Direct Supervision via Audio/Video Communications: AAPA opposes making permanent direct supervision by electronic means of services provided by PAs, in order to minimize “incident to” billing and thereby preserve data integrity.
• Prevention and Management of Chronic Disease: AAPA advocates for increased beneficiary use of Annual Wellness Visits and requests legislative changes to allow PAs to supervise staff performing these visits. We encourage CMS to develop guidance on data and reimbursement expansion and propose various measures to boost primary care. AAPA recommends CMS update policies and work with Congress to authorize PAs appropriately.
• Enhancing Medicare Program Efficiency: AAPA recommends CMS rescind or revise regulatory restrictions to improve access and reduce administrative burdens, citing positive outcomes from temporary COVID-19 flexibilities.
• Payment Accuracy for Global Surgical Packages: AAPA supports transparency but cautions data remain incomplete and recommends further data collection and stakeholder engagement before finalizing revaluations. We request assurance that patients will not face increased costs due to separate post-operative billing and that surgical assistant payments remain unaffected.
• Expansion of Behavioral and Mental Health Services: AAPA requests CMS remove remaining restrictions on PAs certifying inpatient psychiatric care, prescribing and establishing treatment plans for outpatient psychiatry, and inclusion in Community Mental Health Center interdisciplinary teams. We urge CMS to require all CMS-regulated payers to authorize PAs to provide behavioral health services. AAPA supports CMS proposals to add behavioral health services to telehealth coverage, among other provisions.
• Telehealth Services: AAPA supports permanent extension of telehealth flexibilities and advocates for permanent telehealth payment in Rural Health Clinics and Federally Qualified Health Centers. We recommend CMS review specialty requirements for in-person visits prior to mental health telehealth to avoid unnecessary barriers. AAPA requests permanent allowance for providers to use their business practice location rather than home address for enrollment when providing telehealth from home, citing privacy and safety concerns.
• Medicare Shared Savings Program (MSSP) Updates: AAPA supports the proposed updates and inclusion of behavioral health services in the primary care definition for beneficiary assignment. We urge CMS to reconsider removing Social Determinants of Health Risk Assessment from primary care definitions and continue advocating for statutory changes to remove physician-centric assignment language.
• Conversion Factor Update: AAPA stresses the need for a sustainable, equitable long-term payment system and calls on CMS to monitor potential declines in Advanced APM participation.
• Professional Title: AAPA requests CMS refer to the profession as “Physician Assistants/Physician Associates” to ensure consistent and accurate representation of the profession.

For questions, please contact [email protected].

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