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Innovaccer comments on the CMS 2027 Medicare Physician Fee Schedule
Comments from Leaders
On September 14, 2026, Innovaccer submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) in response to the Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS) proposed rule, CMS-1848-P. The letter was signed by Abhinav Shashank, Co-Founder and CEO; David Nace, MD, Chief Medical Officer; and Lisa Bari, MBA, MPH, Vice President of Policy and Partnerships.
Drawing on Innovaccer's experience working with Accountable Care Organizations, health systems, physician practices, payers, and health plans, and on its participation in the CMS ACCESS Model, the letter addresses proposed changes to remote physiologic and remote therapeutic monitoring, the replacement of HCPCS G2211 with the MOD1 and MOD2 modifiers, and the proposed Software as a Medical Service policy. It also responds to CMS requests for information on redesigning primary care, duplicate testing and result sharing, and prospective payment and specialty care within the Medicare Shared Savings Program.
Across these sections, Innovaccer makes the case for policy that matches payment structures to how care is actually delivered today, from clinically integrated remote monitoring models to outcome-aligned payment for technology-enabled primary care, while flagging where proposed rules could create unintended gaps in access or administrative burden for providers and ACOs navigating value-based care.