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The AOA recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on two major 2026 proposed rules: the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (OPPS). In addition, the AOA organized a specialty affiliate sign-on letter opposing harmful provisions in the MPFS rule. Below are the recent examples of how the AOA and its affiliates continue to advocate for fair, evidence-based payment policies that protect patient access and sustain independent practices.
In its comprehensive comment letter, the AOA expressed support for positive steps such as expanded telehealth access, new care management codes and continued stability within the Quality Payment Program. However, the AOA raised serious concerns with CMS’s proposed physician efficiency adjustment, which would cut work RVUs for nearly 7,000 services by 2.5% in 2026. The AOA warned that this approach, untethered to data, would accelerate practice closures, fuel consolidation and undermine access to care. Instead, the AOA urged CMS to work with physicians through the Relative Value Scale Update Committee (RUC) to ensure services are appropriately valued.
Affiliate specialty organizations united in opposition
To amplify this message, 18 osteopathic specialty organizations joined the AOA in a sign-on letter opposing the efficiency adjustment. The affiliates stressed that CMS’s proposal relies on flawed assumptions and would cause unsustainable cuts across most physician specialties.
The AOA also weighed in on the OPPS and Ambulatory Surgical Center (ASC) proposed rule. The letter strongly supported CMS’s efforts to advance site-neutral payment to reduce incentives for hospitals to acquire physician practices and shift care to higher-cost settings. At the same time, the AOA cautioned CMS against undermining physician payment under the MPFS, urging instead that site-neutral policies be pursued through hospital payment systems. The AOA also expressed concern with proposals to introduce new healthcare accreditors, warning that lowering academic standards could jeopardize physician training and patient safety.
Be sure to read the full comments above to learn additional ways in which the AOA is advocating on your behalf.