Make your voice heard by contacting CMS to protect the first reimbursement gains in years for office-based providers.

STEP 1: Go to the Regulations.Gov page for the CY 2026 PFS Proposed Rule.

STEP 2: Fill out the form with your contact information.

STEP 3: Cut and paste the below form letter into the comment form. You are encouraged to include a short paragraph about your center and the types of services you provide.

Dear Administrator Oz:

I am writing to you as a healthcare provider at a center providing services to Medicare beneficiaries in the office-based setting. Many terms are synonymous with the “office-based” setting, including “private practice,” “freestanding,” “nonfacility,” or “place of service 11” and such providers often are independent physicians, small businesses, and rural providers. After seeing my center endure ongoing, significant cuts under the Medicare Physician Fee Schedule (PFS), I now understand that today there are at least 300 services under the PFS where reimbursement is less than direct costs.

It is for these reasons I am grateful to see the Centers for Medicare and Medicaid Services (CMS) implement policies that will result in positive updates for office-based specialty providers for the first time in several years. Specifically, I am writing about the policies in the 2026 PFS Proposed Rule to address site of service payment differentials by reallocating indirect practice expense (IPE) costs from facility-based services to non- facility-based services. Your IPE reallocation policy under the 2026 PFS Proposed Rule is a large part of why my services have seen the first increase under Medicare in recent years. This policy is a welcome first step towards stabilizing my office-based center.

I am aware of data from the American Medical Association showing that over the last few decades there has been a significant drop in private practice physicians and a corresponding increase in physicians in hospital-owned practices. I can say definitively that without policies such as the IPE policy in this regulation, I also would have been forced to take such drastic measures as closing, being bought by a hospital / health system, or unnecessarily converting to an ambulatory surgical center.

I urge you to maintain the IPE policy in the 2026 PFS Final Rule and to build on this policy in future regulations to provide permanent stability to office-based procedural providers.

STEP 4: Hit submit!

Thank you,