Washington, D.C. (September 12, 2025) – In a comment letter to the Centers for Medicare and Medicaid Services (CMS), the Primary Care Collaborative and its Better Health — NOW (BHN) campaign expressed appreciation for several MPFS modernization proposals that “strengthen whole-person primary care.”
The PCC—a nonprofit, nonpartisan multi-stakeholder coalition of 70 member organizations committed to improving the health of the nation by strengthening primary care—and its BHN partners believe the proposal is an important step in fixing Medicare’s flawed payment program, which vastly undervalues primary care.
“For decades, Medicare’s fee-for-service approach to payment has undervalued time-intensive, relationship-based services such as primary and behavioral care,” said PCC President and CEO Ann Greiner. “CMS’s 2026 proposals are an important step toward reversing that harmful trend.”
Greiner adds that research shows primary care, when supported and valued, can also result in better health outcomes.
In particular, the PCC and its BHN partners encouraged CMS to:
- implement efficiency adjustments that more accurately value primary care
- eliminate cost-sharing for Advanced Primary Care Management (APCM) in APCM services
- finalize coverage and payment for add-on Behavioral Health Integration codes
- establish primary care capitation broadly in the Medicare Shared Savings Program (MSSP)
- and shift payment policies to support whole-person primary care, including motivational interviewing, health & well-being coaching
At the same time, PCC urged the agency not to finalize a proposal that would eliminate additional payment that supports screening for unmet needs and upstream drivers of health.
CMS is expected to issue its final regulation early in November, with many provisions likely to go into effect in 2026.