On August 8, the Primary Care Collaborative (PCC) hosted a webinar exploring how the 2026 Medicare Physician Fee Schedule proposed rule could affect primary care. The PCC also provided attendees with recommendations on where to weigh in with CMS on the proposed rule; the recommendations have been compiled in an issue brief available here.
Greiner also asked attendees to send their responses to the PCC so that the PCC can track the community’s reaction to the rule. Comment letters can be sent to PCC Policy Associate Chiyedza Mvundura at cmvundura@thepcc.org.
The webinar opened with analysis from PCC President and CEO Ann Greiner and Ariadne Labs Executive Director Asaf Bitton, who gave high-level takeaways on the provisions most likely to impact primary care.
Greiner highlighted the rule’s bipartisan support and the PCC’s input on the proposed rules. The expanded APCM bundled payment would now include behavioral health integration and reduce administrative burdens, providing a pathway to limited hybrid payments. Pay would also be rebalanced in a way that could improve access and workforce. The rule would also provide more empirical data sources for CMS to rely on when making payment decisions.
Greiner also underscored the importance of the primary care community responding to the draft regulation. She urged attendees to provide feedback to CMS, noting that if primary care stakeholders don’t weigh in, the voices of other interests could instead shape payment structures in ways that don’t support primary care.
Bitton focused on three main areas in the proposed rule continuing a decade-long shift in primary care payment. First is a gradual move away from fee-for-service toward non-visit-based models like advanced primary care management codes. This would support team-based care and reduce administrative burden. Next is a modest increase in resources for primary care, albeit with an overall share of health care spending on primary care still remaining low. Third is a greater commitment from CMS to ensure value-based payments actually reach frontline primary care teams. This includes changes in how services are valued and broader data sources beyond traditional committee input to better capture complex primary care work.
Bitton also reminded attendees of the critical role that feedback and formal responses to the proposed rule play in shaping the final rule, encouraging attendees to read pages relevant to the primary care community and think through their implications.
Following this high-level analysis, Greiner introduced a reaction panel to provide additional feedback and guidance on different provisions. Commentators included:
- Shari Erickson (Chief Advocacy Officer and Senior Vice President, Governmental Affairs and Public Policy – American College of Physicians)
- Daniel Esquibel (Director of Public Policy – Humana)
- Darren Fogarty (Associate Director, Purchaser Value and Policy – Purchaser Business Group on Health)
- Sophia Tripoli (Senior Director of Health Policy – Families USA)
Tripoli stressed that Medicare payment policy shapes the entire health care system, directly affecting patients’ ability to access affordable care. From a consumer perspective, she sees the proposed rule as a major step toward reducing administrative burden and revaluing primary care. There is, however, plenty of room for feedback and a dialogue with the administration.
Fogarty explained how many large employers see advanced primary care as a high-priority, proven strategy to lower costs and improve employee health. As Medicare payment policy strongly influences the commercial market and provider investment decisions, he praised CMS’s proposals and encouraged employers to support and adopt these changes. This is especially true for behavioral health integration.
Erickson highlighted how internal medicine physicians are positively impacted by these changes. However, she cautioned that many provisions need fine tuning still, including the proposed cut to facility-based practice expense payments. She outlined concerns of this proposed statute harming rural hospitals and those working in infectious disease.
Esquibel underscored the importance of value-based care from a payer perspective. Speaking positively of the rule, he highlighted its investment in providers who own and manage the ongoing patient relationship. This is especially apparent through the advanced primary care management services.
Fogarty expanded upon the importance of behavioral health, arguing that integration should be treated as a primary care need. He also supported moving away from fee-for-service payment models toward a hybrid system. He argues that this will reduce administrative burden and allow for more comprehensive preventative care.
Tripoli agreed, highlighting that the COVID pandemic saw fee-for-service reliant providers struggling or even outright failing when patient volume dropped. Those with a value-based or bundled payment models system were more stable. Hybrid payments offer a steppingstone toward more sustainable, value-based payment models for primary care.
Erickson voiced strong support for including preventive services in the bundled payment codes. This would address a major barrier her members endure as patients face cost-sharing for these sort of services.
Esquibel emphasized the need for investing in team-based care. This included continuing key conversations on chronic disease prevention and management. Similarly, there should be further discussion on the potential for new technologies like software as a service and AI to enhance primary care delivery responsibly.
The webinar closed with all panelists urging attendees to provide feedback to CMS on the proposed rule.