Posted in: Government Outreach

Please note: references and footnotes are not included in the web version of this comment. Download the PDF version for reference information

September 11, 2026
The Honorable Mehmet Oz, MD, MBA
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1848-P
P.O. Box 8010
Baltimore, MD 21244-8010

Re: CMS-1848-P – CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies

Submitted electronically via: https://www.regulations.gov

Dear Administrator Oz:

The Accreditation Association for Ambulatory Health Care (AAAHC) appreciates the opportunity to submit comment to the Centers for Medicare & Medicaid Services (CMS) regarding the recently proposed rule entitled Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program.

AAAHC commends CMS for advancing policies that support physician practice sustainability, preserve patient access, strengthen value-based care, modernize quality measurement, and encourage responsible innovation. The proposed rule reflects Medicare’s continued shift toward a more coordinated, accountable, technology-enabled, and patient-centered health care system.

As Medicare continues to evolve, AAAHC believes five principles should guide policy implementation:

  • Preserve patient access through sustainable physician payment policies.
  • Maintain strong organizational readiness as a foundational requirement for successful implementation of payment reform, value-based care, quality improvement initiatives, and emerging technologies.
  • Advance meaningful quality improvement through regulatory efficiency by reducing unnecessary administrative burden and focusing measurement on outcomes that improve patient care.
  • Promote responsible innovation through effective governance and oversight.
  • Leverage nationally recognized accreditation as a strategic partner in advancing quality and accountability.

Reinforcing these principles is mutually beneficial. Sustainable payment supports access. Strong governance supports innovation. Regulatory efficiency strengthens quality improvement. Organizational readiness enables successful implementation of health care transformation. Together, these policies help ensure Medicare beneficiaries continue to receive safe, high-quality care while providing physician practices with the resources and capabilities needed to meet evolving program expectations.

The comments that follow address specific provisions of CMS-1848-P through this broader policy framework. While responsive to the proposed rule, they also reflect AAAHC’s perspective as the nation’s leading independent accrediting organization dedicated exclusively to ambulatory health care.

Introduction

Founded in 1979, AAAHC is the nation’s leading independent accrediting organization dedicated exclusively to advancing quality in ambulatory health care. AAAHC is a private, independent 501(c)(3) nonprofit organization that accredits more than 6,800 organizations committed to high-quality, patient-centered care, including more than 1,000 Medicare-certified ambulatory surgery centers (ASCs) accredited under CMS deeming authority.

For more than four decades, AAAHC has partnered with providers, health systems, government agencies, and policymakers to advance quality, patient safety, and continuous improvement across the ambulatory care continuum. AAAHC accredits a broad range of ambulatory care settings, including HRSA, Federally Qualified Health Centers (FQHCs), U.S. Coast Guard health care facilities, Indian Health Service/Urban Indian Health (IHS/UIH) centers, student health centers, medical and dental group practices, and office-based surgery centers.

CMS-1848-P reflects the continued evolution of the Medicare program beyond annual payment updates toward a broader strategy that strengthens physician practice, advances value-based care, modernizes quality measurement, encourages responsible innovation, and promotes long-term program sustainability. While many provisions address payment methodologies, coding policies, quality reporting requirements, and operational changes, the proposed rule also advances broader policy objectives that will influence how physician practices organize, govern, and deliver care in the years ahead.

AAAHC supports CMS’s continued efforts to modernize Medicare in ways that improve quality, preserve patient access, and encourage innovation while maintaining accountability. As physician practices assume increasing responsibility for care coordination, longitudinal patient-centered care management, quality outcomes, technological transformation, and population health management, organizational capability becomes as important as reimbursement policy. Payment reforms establish incentives, but sustainable improvements in quality and patient outcomes ultimately depend upon effective governance, physician leadership, operational resilience, workforce readiness, and a culture of continuous improvement.

Accordingly, AAAHC’s comments focus on those aspects of the proposed rule where the organization can provide unique value as a Medicare-approved Accrediting Organization dedicated exclusively to ambulatory health care. Rather than addressing every payment methodology or coding proposal, these comments emphasize the organizational capabilities necessary to successfully implement Medicare policy while advancing patient safety, quality improvement, physician engagement, and continuous readiness across diverse ambulatory settings.

The comments that follow address selected provisions of CMS-1848-P. The absence of comments on other provisions should not be interpreted as support or opposition.

II. Provisions of the Rule for the PFS
B. Determination of PE RVUs
4. Changes to Direct PE Inputs for Specific Services
D. Updates to Practice Expense (PE) Methodology-Site of Service Payment Differential

AAAHC appreciates CMS’s continued examination of site-of-service payment policies and practice expense methodologies. Consistent with our prior comments, AAAHC is concerned that payment policies that narrow reimbursement differentials without fully accounting for the operational realities of independent physician practices may contribute to continued consolidation among healthcare providers. Independent physician practices often serve as critical access points, particularly in rural, underserved, and resource-constrained communities.

AAAHC encourages CMS to evaluate physician payment policies through two complementary objectives: improving quality and preserving patient access. These objectives reinforce one another. Physician practices require sufficient financial and operational stability to invest in workforce development, quality improvement, technological transformation, cybersecurity, care coordination, and continuous organizational improvement. CMS should continue considering the cumulative operational impact of federal requirements on physician practices, particularly independent practices and organizations serving rural, Tribal, frontier, and medically underserved communities.

As Medicare payment and delivery models continue evolving, preserving physician practice sustainability remains essential to ensure beneficiaries maintain timely access to high-quality ambulatory care. AAAHC encourages CMS to carefully evaluate whether future payment policies strengthen physician practices’ ability to invest in quality improvement and patient-centered care while maintaining access to care for Medicare beneficiaries.

C. Payment for Medicare Telehealth Services
4. Changes to Teaching Physicians’ Billing for Services Involving Residents or Teaching Physicians with Virtual Presence

AAAHC supports CMS’s proposal to permit teaching physician billing when either the teaching physician or the resident is physically present with the beneficiary during services involving virtual participation by the other clinician. This proposal appropriately recognizes practical operational realities while preserving meaningful physician supervision and the educational value of resident training. By reducing unnecessary logistical barriers to care, the proposal offers greater flexibility for providers and may further promote access to care. As this flexibility increases, it remains critical to ensure that teaching physician supervision is appropriately documented, with clear accountability for both patient care and educational oversight. These safeguards are consistent with existing CMS telehealth and teaching physician supervision policies, which emphasize real-time interactive audio-video communication, immediate availability of the supervising physician, and appropriate clinical oversight of resident furnished services. CMS and HHS telehealth guidance further support verification of patient location, emergency response planning, and clear process for escalation to in-person care when telehealth is insufficient to safely evaluate or manage the patient’s condition. Accordingly, AAAHC encourages CMS to incorporate these patient safety principles into any expanded telehealth teaching physician framework.

D. Valuation of Specific Codes Including Potentially Misvalued Services Under PFS
3. Methodology for the Direct PE Inputs to Develop PE RVUs
b. Common Refinements
(48) Remote Monitoring

AAAHC supports CMS’s efforts to strengthen program integrity and ensure that remote monitoring services are furnished as part of a meaningful, clinically integrated treatment plan. Remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services have expanded access to care, supported chronic disease management, improved continuity of care, and enabled patients to receive appropriate and convenient monitoring. Consistent with AAAHC’s longstanding support for telehealth and other technology-enabled care models, these services can improve access, accountability, and patient engagement when provided in accordance with appropriate quality standards.

AAAHC agrees with CMS that remote monitoring services should remain integrated within the patient’s broader care team and that billing practitioners must maintain meaningful oversight and accountability for services furnished under their supervision. AAAHC shares CMS’s concern that arrangements lacking sufficient clinical coordination, practitioner involvement, or patient-specific treatment planning may undermine the intended purpose of RPM and RTM services. For example, programs should establish actionable thresholds and response timeframes for rapid weight gain and heart failure, worsening blood pressure or glucose control, or declining adherence to a prescribed therapeutic regimen, with a clearly identified practitioner responsible for follow-up.

However, AAAHC encourages CMS to carefully evaluate the potential access implications of prohibiting all third-party service arrangements. Many physician practices, particularly smaller, rural, and independent practices, may rely on contracted vendors for certain operational and technology-support functions that would otherwise be difficult to provide internally. A blanket prohibition could unintentionally reduce beneficiary access to remote monitoring services, particularly in medically underserved communities.

Consistent with AAAHC’s accreditation philosophy, organizations implementing remote monitoring programs should maintain the governance, quality management, and operational infrastructure necessary to support safe, coordinated, and accountable care delivery. Therefore, AAAHC recommends that CMS focus on ensuring sufficient clinical integration, practitioner oversight, and accountability regardless of whether certain operational functions are supported by employed staff or qualified contracted entities. The critical consideration should be whether the billing practitioner maintains ongoing responsibility for the patient’s care, treatment plan, and monitoring activities, and whether all applicable Medicare requirements and quality standards are met.

More broadly, AAAHC believes that remote monitoring and other technology-enabled care services should be viewed as an extension of comprehensive ambulatory care rather than as standalone technology programs. Successful implementation depends not only on reimbursement policy, but also on an organization’s ability to integrate remote monitoring into clinical workflows, quality improvement activities, patient communication, care coordination processes, and ongoing physician oversight. When supported by appropriate governance and quality infrastructure, remote monitoring can strengthen patient engagement, enhance continuity of care, and improve access while maintaining accountability for clinical outcomes.

Ultimately, AAAHC supports policies that promote patient-centered, coordinated care while preserving access to innovative care delivery models. As remote monitoring policies are finalized, AAAHC encourages CMS to implement safeguards that address misuse and fraud without creating unnecessary barriers for providers that are appropriately integrating remote monitoring into high-quality, coordinated patient care.

(59) Revisions to Teaching Physician Policy Related to the Primary Care Exception

AAAHC supports CMS’s proposal to expand the primary care exception to permit additional evaluation and management (E/M) services furnished by residents under direct supervision when the teaching physician determines the arrangement is clinically appropriate. The proposal appropriately recognizes the importance of expanding access to care while enhancing the education and training of future clinicians through appropriately supervised clinical experiences.

Teaching physicians and graduate medical education (GME) programs are best positioned to assess resident competency, patient complexity, and appropriate supervision requirements. Allowing greater flexibility for residents to perform level 4 and level 5 office/outpatient E/M visits recognizes teaching physicians’ clinical judgment while giving residents meaningful opportunities to develop the skills necessary for independent practice. Appropriate resident autonomy strengthens educational experiences, promotes professional development, and may improve patient access to timely care. Accordingly, AAAHC supports removing the “lower and mid-level complexity” language to permit billing of certain level 4 and level 5 office/outpatient E/M codes.

AAAHC also emphasizes that expanded resident autonomy should be accompanied by appropriate oversight and accountability. GME programs implementing this flexibility should maintain comprehensive supervision protocols, clear documentation requirements, and ongoing assessment of resident competency. Teaching physicians must retain ultimate responsibility for patient care and clinical decision-making, and documentation should continue to demonstrate compliance with supervision requirements and clearly identify the respective roles of the resident and teaching physician. Supervision protocols should require prompt teaching-physician involvement for unstable vital signs, acute neurological symptoms, high-risk medication decisions, significant diagnostic uncertainty, or a possible need for higher acuity care. This approach supports patient safety, transparency, quality oversight, and the educational value of residency training.

(61) Software as a Medical Service (SaMS) Laboratory Analysis

AAAHC supports CMS’s proposal to adopt the term Software as a Medical Service (SaMS) in place of Software as a Service (SaaS) for software-enabled technologies that support clinical decision making through algorithmic analysis. We agree that the proposed terminology more accurately reflects the clinical and diagnostic functions performed by these technologies and appropriately distinguishes healthcare-focused software from general cloud-based information technology services. As CMS notes, software-based technologies with novel functions are becoming increasingly integrated into care delivery across outpatient settings to support clinical decision-making. A more precise and clinically relevant definition establishes an important foundation for future Medicare coverage, payment, and oversight policies.

AAAHC also supports CMS’s efforts to create a more consistent payment and policy framework for algorithmic analyses that perform comparable diagnostic or clinical decision-support functions regardless of the underlying data source. As these tools continue to evolve, a uniform approach across care settings and technology types can help promote transparency, predictability, and appropriate valuation while reducing potential confusion regarding how software-enabled clinical technologies are categorized and reimbursed.

While AAAHC recognizes the importance of establishing appropriate payment methodologies for SaMS technologies, the safe and effective deployment of these tools ultimately depends upon the governance structures within health care organizations that adopt them. SaMS technologies may assist clinicians by identifying patterns, generating risk assessments, or supporting diagnostic decision-making; however, they do not replace the professional judgment, accountability, or clinical responsibility of licensed healthcare practitioners. As CMS continues to expand policies governing SaMS technologies, AAAHC encourages recognition of the critical role organizational governance plays in ensuring these tools are implemented responsibly and monitored appropriately. This oversight becomes particularly important as certain algorithmic analyses are increasingly separated from the CLIA-regulated laboratories or entities that generated the underlying clinical data, creating a greater need for clear accountability, performance monitoring, and quality assurance mechanisms.

Through our recently released, CMS-approved v45 Accreditation Standards, AAAHC establishes governance expectations for the responsible use of artificial intelligence (AI) and other software-enabled technologies across ambulatory care settings. These standards address broader principles of governance, accountability, risk management, workforce preparedness, and continuous quality improvement, providing organizations with practical frameworks for the safe and effective integration of emerging technologies. As software-enabled clinical technologies continue to evolve, accreditation can help organizations operationalize governance expectations in a manner that remains adaptable to emerging innovations.

AAAHC encourages CMS to continue evaluating whether existing standards and guidance adequately address interoperability, accountability, transparency, patient privacy, bias mitigation, and safety concerns associated with software-enabled clinical technologies. As CMS advances SaMS policies, nationally recognized accrediting organizations can serve as important partners in translating federal policy objectives into day-to-day operational practices. Accreditation complements CMS oversight by promoting consistent governance, continuous quality improvement, and organizational readiness, helping ensure that innovation advances alongside patient safety, quality, and accountability.

E. Request for Information: Redesigning Primary Care to Make America Healthy Again

AAAHC appreciates CMS’s comprehensive effort to redesign primary care and evaluate the future of care delivery, care management, technology enablement, and prospective payment models. Strong primary care serves as the foundation for prevention, chronic disease management, behavioral health integration, care coordination, and improved health outcomes. Throughout this request for information (RFI), CMS appropriately recognizes that these core components are increasingly interconnected and must be supported through a coordinated, longitudinal approach to care.

AAAHC also commends CMS for its continued efforts to recognize the unique complexity and resource requirements associated with primary and longitudinal care. CMS’s efforts to better distinguish and appropriately value the range of services provided across longitudinal, acute, and consultative care settings represent important steps toward more accurately recognizing the work required to deliver effective, patient-centered primary care.

As physician practices assume greater accountability for quality, cost, and population health outcomes, organizational readiness becomes an increasingly important determinant of success. Sustainable participation in advanced primary care and value-based care models requires infrastructure that supports care coordination, preventive services, behavioral health integration, patient engagement, quality improvement, and effective use of technology. AAAHC Accreditation Standards provide an established framework for these capabilities and can help inform the defining characteristics of longitudinal care, including continuity, communication, comprehensive care planning, and coordinated management across care settings.

AAAHC encourages CMS to continue refining payment policies that recognize and support the full scope of primary care while minimizing unnecessary administrative burden. Any new coding, payment, or attribution methodologies should align with clinical workflows, reduce documentation complexity, and promote high-quality, patient-centered health care. Grounding these policies in evidence-based standards and proven quality frameworks will help ensure that payment reforms advance both accountability and improved patient outcomes.

3. Care Management Code ‘Family’

AAAHC supports CMS’s ongoing efforts to modernize and simplify care management services, recognizing their critical role in improving outcomes for beneficiaries with chronic and complex conditions. We appreciate CMS’s work to expand and refine the care management code family, including Advanced Primary Care Management (APCM) and Principal Care Management (PCM), as well as its efforts to reduce unnecessary administrative burden that may limit adoption of these services.

As CMS has recognized, care management is most effective when it supports ongoing patient relationships, coordinated care, and proactive management of chronic conditions. AAAHC supports efforts to streamline documentation requirements, including the removal of burdensome time-based reporting requirements where appropriate, while maintaining safeguards necessary to ensure program integrity and accountability.

As CMS considers opportunities to reduce fraud, waste, and abuse, policies should focus on demonstrating meaningful patient engagement, care plan development and maintenance, coordination of services, and documented interventions that support patient needs and health outcomes. Verification mechanisms should emphasize evidence of the care delivered and the patient benefit rather than imposing overly prescriptive documentation requirements that subsequently discourages participation.

To further strengthen the effectiveness and utilization of care management services, CMS should consider opportunities to better integrate care management activities with longitudinal primary care, support technology-enabled care delivery models, and establish flexible supervision approaches that maintain patient safety while accommodating evolving models of care. Technology can enhance communication, monitoring, patient outreach, and care coordination; however, reimbursement policies should continue to recognize the importance of clinical oversight and professional judgment. CMS should also ensure that services are delivered by qualified personnel and documented in a manner that demonstrates meaningful patient engagement and measurable clinical value without imposing excessive administrative complexity on practitioners.

AAAHC encourages CMS to prioritize policies that support whole-person, patient-centered care and promote outcome-focused approaches that improve health, reduce fragmentation, and enhance care coordination across settings. As CMS considers future payment structures and technology-enabled care models, policies should continue to reward longitudinal clinician-patient relationships, meaningful care coordination, and measurable improvements in beneficiary outcomes while maintaining appropriate accountability for services provided.

4. Payment Implications of Technology Enablement of Primary Care

AAAHC strongly supports CMS’s recognition of the transformative potential of technology and AI in primary care. As clinical AI tools and software-enabled clinical technologies become more prevalent, it is essential to ensure that their adoption enhances, rather than replaces, the professional judgment and accountability of licensed practitioners.

AAAHC encourages CMS to prioritize policies that focus on patient outcomes, safety, continuity of care, and meaningful clinical engagement rather than technology utilization alone. Technology should serve as a tool to support high-quality, patient-centered care and enable more effective clinical decision-making, care coordination, and operational efficiency across care settings.

Successful implementation of technology-enabled care requires strong governance frameworks. AAAHC’s v45 Accreditation Standards establish expectations for organizations implementing artificial intelligence and software-enabled technologies, emphasizing governance, risk assessment, cybersecurity protections, transparency, workforce education, human oversight, and continuous quality improvement as essential safeguards for responsible innovation. These principles help ensure that technology is implemented in a manner that promotes patient safety, maintains public trust, and supports equitable care delivery.

AAAHC also encourages CMS to support policies that advance interoperability, protect patient privacy, and facilitate the integration of technology-enabled care management and AI-assisted clinical decision support into existing care models. As CMS evaluates future payment and delivery system reforms, consideration should be given to approaches that reward demonstrable improvements in care quality, patient outcomes, care coordination, and access rather than technology adoption alone. Payment policies should remain sufficiently flexible to accommodate rapidly evolving technologies while maintaining appropriate clinical oversight, transparency, and accountability. CMS should also continue monitoring for unintended consequences, including potential impacts on documentation practices, coding behavior, and care utilization patterns, to ensure that technology adoption advances high-value, patient-centered care.

By aligning technology policy with established quality and accreditation principles, CMS can help create a balanced framework that fosters innovation while ensuring that software-enabled clinical technologies and AI are deployed safely, effectively, and in ways that improve outcomes for patients and practitioners alike.

5. Technology and AI-Augmentation in Primary Care Via the Medicare AWV

AAAHC appreciates CMS’s focus on preventive care and the potential for technology to enhance the effectiveness and personalization of the Annual Wellness Visit (AWV). We support the exploration and thoughtful use of AI-enabled tools to improve pre-visit data collection, risk assessment, care planning, and post-visit follow-up. As CMS considers future policies in this area, technology should support, not replace, the clinician-patient relationship and the shared decision-making process. The value of the AWV remains rooted in meaningful patient engagement, individualized assessment, and professional clinical judgment.

AAAHC encourages CMS to align technology-enabled AWV policies with established quality and accreditation principles that emphasize patient-centered care, health literacy, cultural responsiveness, and comprehensive care planning. Technology and AI-enabled tools may support several AWV functions, including pre-visit health risk assessments, collection and summarization of health information, identification of preventive care gaps, personalized education, and follow-up communications. When a tool identifies a new risk, such as cognitive impairment, fall risk, depression, or an overdue cancer screening, the workflow should include clinician confirmation, patient counseling, referral when appropriate, and closed-loop follow-up so that detection does not create an unmanaged care cascade. Essentially, these tools should complement, rather than replace, clinical judgment and meaningful engagement between patients and practitioners. We encourage CMS to evaluate these innovations based on their impact on preventive service utilization, risk factor management, patient engagement, and health outcomes.

Finally, CMS should continue to address regulatory, billing, and supervision barriers that may unnecessarily limit the adoption of effective technology-enabled AWV models while maintaining appropriate safeguards for patient safety, clinical oversight, and program integrity. As CMS evaluates new approaches, success should be measured not by increases in AWV volume, documentation completeness, or coding intensity alone, but by demonstrable improvements in prevention, care planning, patient experience, and health outcomes. By balancing innovation with accountability, CMS can strengthen the AWV’s role in advancing preventive care and improving outcomes for Medicare beneficiaries.

III. Other Provisions of the Proposed Rule
D. Proposed Changes to the Ambulatory Specialty Model (ASM)
2. Proposed Changes to Provisions of the Ambulatory Specialty Model (ASM)
c. Data Submission

AAAHC appreciates CMS’s continued efforts to simplify data submission requirements for the Ambulatory Specialty Model (ASM) performance categories while maintaining meaningful quality measurement and program integrity. We support policies that reduce unnecessary administrative burden and recognize the operational realities and limitations frequently faced by small and independent practices.

Quality ASM Performance Category Data Submission for ASM Participants in Small Practices

AAAHC supports CMS’s proposal to consolidate and clarify the regulatory text regarding quality data submission for Ambulatory Specialty Model (ASM) participants in small practices. AAAHC also supports CMS’s clarification that ASM participants in small practices may submit quality measure data at either the group (TIN) or individual (TIN/NPI) level. This flexibility appropriately recognizes the operational realities and varying administrative capacities of small practices while preserving meaningful quality measurement and accountability. Clear, accessible reporting requirements can reduce unnecessary administrative burden and help support participation.

AAAHC believes that continued efforts to simplify and clarify quality reporting requirements are particularly important for small and independent practices, which often face resource constraints when implementing reporting and performance measurement programs. We support CMS’s proposed revisions and appreciate the agency’s ongoing efforts to improve the usability and transparency of program requirements.

Improvement Activities ASM Performance Category Data Submission

AAAHC appreciates CMS’s responsiveness to stakeholder feedback regarding group-level attestation for improvement activities. Allowing ASM participants to report improvement activity data at either the group (TIN) or individual (TIN/NPI) level provides important flexibility while continuing to support team-based care.
AAAHC agrees that this approach may help prevent unintended scoring consequences for clinicians who have completed required activities but could otherwise be adversely affected by group-level reporting. Providing both reporting options enables organizations to select the method that best reflects their circumstances and data submission preferences.

AAAHC supports CMS’s efforts to balance administrative simplicity, accountability, and fairness and believes this added flexibility will help encourage continued participation in the ASM.

Generally, AAAHC encourages CMS to continue prioritizing policies that reduce unnecessary administrative complexity, promote clarity, and support meaningful quality improvement, particularly for small practices and other resource-constrained settings. As organizations adapt to evolving reporting requirements, clear guidance and flexible options are critical to supporting participation, especially among small practices and diverse care settings. AAAHC’s accreditation standards emphasize the importance of robust data collection, documentation, and continuous quality improvement, and we believe that aligning regulatory requirements with these principles will help advance both accountability and improved patient outcomes.

E. Limiting Medicare Coverage of Certain Individuals

AAAHC recognizes CMS’s responsibility to implement statutory changes regarding Medicare eligibility and enrollment provisions. As CMS finalizes implementation policies, AAAHC encourages careful consideration of the potential effects on beneficiary access to care, continuity of treatment, patient transitions, and administrative complexity. Safeguards to preserve continuity of care are especially important for beneficiaries receiving dialysis, cancer therapy, transplant care, home oxygen, specialty medications, behavioral health treatment, or active post-acute care. To mitigate disruptions, CMS should consider providing advance notice of coverage changes, establishing temporary protections for medication and treatment continuity, offering expedited appeals, and facilitating handoffs to alternate coverage options or providers. Clear communication, comprehensive beneficiary education, streamlined appeals and re-enrollment processes will be critical to minimizing disruptions in care and preserving access for affected individuals.

X. Request for Information (RFI) on Duplicate Laboratory Testing, Imaging, and Result Sharing and Interoperability

AAAHC appreciates CMS’s efforts to advance interoperability and improve the exchange of laboratory and imaging information across the healthcare system. Seamless access to diagnostic information is foundational to coordinated, high-quality care and can reduce unnecessary duplicate testing, improve clinical decision-making, strengthen care coordination, and promote more efficient use of healthcare resources.

Incentives for Adoption and Implementation

AAAHC supports CMS’s consideration of incentives to encourage the adoption of interoperability solutions, especially for ambulatory organizations, independent practices, rural providers, and smaller health care facilities. Meaningful adoption requires substantial investments in technology, workforce training, cybersecurity, and workflow redesign. Incentive programs should help offset these costs and promote sustainable interoperability, with particular attention to organizations serving rural, Tribal, frontier, and medically underserved communities.

Conformance Tools, Certification, and Implementation Guidance

AAAHC supports initiatives that improve consistency and reliability in health information exchange. Expanded conformance testing tools, certification programs, and clear implementation guidance can help organizations achieve interoperability objectives and reduce variability across settings. Educational resources and standardized approaches are essential, and nationally recognized accreditation programs can serve as a complementary mechanism to evaluate governance, operational readiness, and continuous improvement.

Accountability for Repeat Imaging

AAAHC agrees that timely access to prior diagnostic information can reduce unnecessary duplication of services and support more efficient, coordinated care. However, repeat laboratory testing or imaging may be clinically appropriate in many circumstances, including changes in patient condition, emergency care, trauma, stroke, evolving diagnoses, or concerns regarding test quality or completeness. Failures in information exchange may also result from multiple factors, including technical limitations, vendor capabilities, cybersecurity, and workflow differences. Any accountability framework should carefully evaluate underlying reasoning and causes of duplicate testing before assigning responsibility. AAAHC recommends prioritizing system improvements, corrective action, and collaboration among stakeholders before pursuing punitive measures. CMS should also adopt a narrow and clinically appropriate definition of “duplicate” testing that excludes repeat services performed when a patient’s condition has changed, the prior result is no longer current, specimen or image quality is inadequate, the result cannot be accessed within the timeframe necessary for clinical decision-making, or serial testing is required to monitor response. Such safeguards will help ensure that efforts to reduce unnecessary utilization do not inadvertently compromise clinical judgment, patient safety, or timely access to appropriate care.

Barriers to Laboratory Interoperability and Policy Levers

Despite established standards, barriers to laboratory interoperability persist, including financial costs, technical complexity, workforce limitations, and vendor inconsistencies. AAAHC encourages CMS to consider incentives, education, technical assistance, and implementation support to facilitate adoption, especially for resource-limited organizations. Administrative simplification and standardized approaches are also important to avoid unnecessary complexity or duplicative reporting.

Minimum Data Standards and Rural Considerations

AAAHC supports the establishment of minimum data standards for result shareability. However, CMS should carefully evaluate operational readiness and provide phased implementation, technical support, and flexibility for organizations facing substantial barriers, especially in rural and underserved areas. Technology adoption should not unintentionally disadvantage providers serving these populations. At minimum, exchanged results should provide the information clinicians need to identify the patient, interpret the findings, determine when the test was performed, and access related images when appropriate.9 Policies should ensure critical results are communicated, and follow-up responsibilities are clearly assigned.

Governance and Quality Improvement

Effective interoperability depends not only on technical standards but also on governance structures that support data integrity, cybersecurity, workforce competency, and continuous quality improvement. AAAHC accreditation standards provide a framework for these organizational capabilities and can help ensure that interoperability initiatives are implemented safely and effectively.

AAAHC commends CMS for its leadership in addressing duplicate testing and advancing interoperability. We encourage continued collaboration with stakeholders to develop policies that balance program integrity, clinical flexibility, and equitable access to high-quality diagnostic services. By aligning interoperability requirements with established quality and accreditation principles, CMS can strengthen information exchange, reduce unnecessary burden, and improve care coordination and patient outcomes.

AAAHC appreciates the opportunity to comment on CMS-1848-P. As Medicare continues evolving toward value-based care, technological transformation, and greater organizational accountability, AAAHC encourages CMS to continue viewing nationally recognized accrediting organizations as implementation partners that help translate policy into operational excellence. Accreditation strengthens governance, physician leadership, patient safety, quality improvement, organizational resilience, and continuous readiness. These capabilities closely align with the broader objectives of Medicare policy and provide opportunities to improve quality while reducing unnecessary duplication and administrative burden.

AAAHC values its longstanding partnership with CMS and appreciates CMS’s continued collaboration with accrediting organizations in advancing high-quality ambulatory care. We look forward to working with CMS to develop policies that strengthen organizational capability, improve patient outcomes, and ensure Medicare beneficiaries continue to receive safe, high-quality care in the most appropriate setting.

Thank you for your consideration of these comments. For any questions, please contact us at 847-853-6060 or CEO@aaahc.org.

Respectfully submitted,

President & Chief Executive Officer
Accreditation Association for Ambulatory Health Care (AAAHC)