Milbank Submits Comment on Proposed Medicare Physician Fee Schedule Change  

On September 11, 2026, The Milbank Memorial Fund submitted a public comment in response to the Centers for Medicare and Medicaid Services (CMS) 2027 Medicare Physician Fee Schedule Proposed Rule and Request for Information on Redesigning Primary Care to Make America Healthy Again. Citing its annual Heath of US Primary Care Scorecard series showing weakening investment in primary care and growing workforce shortages amid rising rates of chronic disease, the Fund agrees that reforming the structure and level of primary care payments is central to reversing these trends. In the letter, Milbank Memorial Fund President Debra Lubar offered comments on select provisions, including the following suggestions. 

Create a panel to advise on service valuation. The Fund supports CMS’s proposed changes to how it values health care services, including its shift from basing prices on a limited survey to using empirical state data. The Fund encourages CMS to establish a permanent panel of technical experts to advise on data sources and valuation methods. 

Eliminate cost-sharing for Advanced Primary Care Management (APCM) services and make permanent temporary coaching codes. Given that even a small copay can deter patients from seeking care, the Fund urges CMS to eliminate beneficiary cost-sharing for all services that fall under the APCM billing code. The Fund also supports permanent status for temporary health coaching codes, and expanding their use to FQHCs and RHCs, to encourage whole-person primary care. 

Considerations for population-based hybrid payment. The Fund supports population-based hybrid payments, which will give practices the flexibility they need to deliver whole-person care while receiving FFS payments that accurately reimburse them for services delivered. To effectively establish prospective primary care payment in the Medicare Shared Savings Program, the Fund recommends that CMS ensure: 

• Payment levels are sufficient to drive meaningful improvement 
• Payments reach primary care clinicians, including those working in large health systems. 
• Prospective payment covers the appropriate scope of services, including those that fall outside the office visit or require flexibility, such as virtual communications 

Add supports for incentives to participate in value-based care. The Fund supports encouraging primary care practices to engage in value-based care. The Fund suggests CMS also: increase transparency into the flow of new funds to ensure resources are reaching frontline practices; support practices in building capacity for accountable care organization participation; and open the incentives to federally qualified health centers (FQHC) and rural health clinics (RHCs). 

Support both technology and relationships. Finally, the Fund appreciates CMS’s interest in how technology, particularly AI, could change primary care delivery and payment. Prospective payments would give clinicians the resources to adopt these tools. At the same time, the Fund believes that “the most powerful lever for improving outcomes and containing costs remains an ongoing trusted relationship with a primary care team.”