The Alliance for Connected Care was pleased to provide feedback on proposed CY2027 polices under the Physician Fee Schedule. The Alliance continues to applaud the Administration’s focus on advancing technology-enabled models of care that support better health outcomes. We share the Centers for Medicare and Medicaid Services goal of strengthening oversight of technology-enabled care, including remote monitoring. However, we are deeply concerned that the effect of the proposed remote monitoring policies would be the loss of access to care for millions of Medicare beneficiaries, with particularly severe consequences for rural communities and patients served by small and independent practices.

The Alliance’s top recommendations include:

  • The Alliance urges CMS to not finalize its proposed remote monitoring policies as written. At minimum, CMS should delay implementation and work with stakeholders to develop a more balanced approach that preserves beneficiary access while establishing targeted, evidence-based safeguards against fraud, waste, and abuse.
  • The Alliance recommends that CMS reconsider its proposed practice expense methodology for care management services. We are concerned that these changes do not account for real costs and could set an alarming precedent for other virtual care services with practice expense costs.
  • The Alliance requests that CMS ensure the telehealth modifiers being implemented through sub-regulatory guidance are meaningful and nuanced in capturing the data which could have long-term implications for telehealth policymaking.
  • The Alliance encourages CMS not to adopt proposed changes to telehealth critical care consultations and maintain alignment between telehealth and in-person care.
  • Recognizing the inherent link between accelerating technology-enabled care on the path to outcome aligned payment – we call on CMS to create additional provider-accessible, technology-enabled, outcome-based care management pathway.
  • The Alliance welcomes CMS’s Make America Healthy Again RFI and looks forward to advancing AI-enabled care delivery through concrete payment pathways. Specifically, the Alliance urges CMS to consider broader modernizations to communications-based technology services to better facilitate their use – making these services easier to provide and allowing for AI-enabled care, while ensuring these changes do not lead to overutilization.

Read the letter here or below:

Alliance for Connected Care CY 2027 PFS Comments - Sept 1 2026