AAEM Letter in Response to Proposed Medicare Physician Fee Schedule Rule

Dear Administrator Oz:

The mission of the American Academy of Emergency Medicine (AAEM) is to fight for high-quality patient care delivered by board-certified emergency physicians and champion a fair and equitable workplace for emergency physicians through advocacy and education. AAEM appreciates the opportunity to provide comments on the CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule.

We align with and echo the American Medical Association’s (AMA) draft comments and recommendations on this proposed rule. In particular, AAEM emphasizes the following priorities for emergency medicine:

Medicare Physician Payment Stability

  • We support AMA’s call for permanent, inflation-based updates to the physician payment system.
  • Emergency physicians care for patients on the frontline providers and practice costs have sharply risen, yet Medicare reimbursement has not kept pace. This gap threatens access to specialized emergency care, especially in rural and safety-net hospitals.

Support for Independent Practice

  • As consolidation accelerates, AAEM stresses that emergency physicians must remain able to practice independently. Payment policies that promote monopolies that are harmful to the public, and disproportionately disadvantage smaller practices and local emergency physician groups will ultimately harm patient access to emergency care.

Quality Payment Program (QPP)

  • We echo AMA’s recommendations to reduce administrative burden in QPP reporting. Emergency physicians face unique challenges with attribution, risk adjustment, and episodic patient encounters. Streamlining measures to better reflect emergency practice realities is essential.

Conclusion

AAEM appreciates CMS’ efforts to strengthen Medicare and ensure patient access. However, without sustainable physician payment reforms and careful reconsideration of the efficiency adjustment and practice expense methodologies, emergency medicine practices—and the patients who rely on us—will be at risk.

We urge CMS to adopt the AMA’s recommendations and to further consider the unique role of emergency physicians in safeguarding the nation’s healthcare safety net.

Sincerely,
The Board of the American Academy of Emergency Medicine (AAEM)