Alliance for Connected Care Response to CY26 Medicare PFS

The Alliance for Connected Care responded to the Centers for Medicare and Medicaid Services (CMS) Calendar Year (CY) 2026 Medicare Physician Fee Schedule proposed rule. The Alliance respectfully urged CMS to continue to work with Congress and other federal agencies to ensure long-term certainty and access to the full spectrum of virtual care options for Medicare beneficiaries.

The Alliance appreciated the strong support of virtual care by the Trump Administration and emphasized the following:

The Alliance is disappointed that CMS did not address provider enrollment and billing concerns related to the reporting of address for a telehealth service offered from a provider’s home or other non-clinical location. This policy will end December 31, 2025. A lapse in current policy will dramatically affect the virtual care workforce, while creating substantial new administrative burdens on health care providers offering virtual care.
The Alliance is very concerned by the potential end of virtual supervision for teaching physicians and requests that CMS provide a year extension of this flexibility prior to making any decision that would so drastically affect the medical workforce and the preparation of new clinicians to offer telehealth. The Alliance appreciates the broader modernization of virtual supervision in the rulemaking.
The Alliance applauds CMS for its proposal to streamline the telehealth service list review process. As the Alliance commented in our response to the CY 2023 and 2024 Physician Fee Schedule, there should not be a need for CMS to separately evaluate whether providing a service itself provides clinical value, and it can meet all clinical requirements when offered through telehealth.
The Alliance applauds CMS for its changes to address the sustainability and access to remote patient monitoring in Medicare. We support the new codes, and the use of the CY2026 OPPS geometric mean cost (GMC) data for valuation, as long as some tweaks are made to this proposal. On a related point, we continue to call for a broader review of technology and software-driven practice expenses in Medicare.
The Alliance supports CMS actions to expand virtual care as part of the Ambulatory Specialty Model and Diabetes Prevention Program, however recommends specific changes to accelerate virtual care and potentially dramatically strengthen the outcomes of both programs.

Read the full letter here or below: