APMA submitted three comment letters in January. Two addressed potential changes in future MIPS performance years, and one was in response to the proposed rule for the 2026 CY Medicare Advantage Part D Policy.
Recommendations for 2026 Podiatry Specialty Measure Set (January 31)
APMA submitted comments to CMS on January 31 in response to its request for recommendations and changes to the 2026 specialty measure sets. APMA made two recommendations:
Additionally, APMA again highlighted significant concerns about the limitations of MIPS measures available to podiatrists, particularly as related to the topped-out measures.
2026 Draft Podiatry MIPS Value Pathways (MVP) Candidate
APMA expressed appreciation to CMS on January 24 for accepting most of its recommendations related to the Draft Podiatry MVP Candidate, while also expressing continued concerns related to the non-pressure ulcer cost measure that was included.
2026 CY Medicare Advantage Part D Policy and Technical Changes Proposed Rule
APMA submitted comments and recommendations on January 27 in response to CMS's proposed rule addressing the 2026 CY Medicare Advantage Part D Policy and Technical Changes. APMA focused on the sections related to Improving Access—Enhancing Rules on Internal Coverage Criteria and Enhancing Health Equity Analyses: Annual Health Equity Analysis of Utilization Management Policies and Procedures. APMA reiterated transparency concerns related to Medicare Advantage Organization (MAO) plans’ coverage and payment policies, particularly that MAO plans are reducing and/or denying payments for services otherwise covered under Medicare fee-for-service. APMA indicted that more closely aligning Medicare Advantage plan policies to existing Part B policies would provide greater consistency and less confusion for Medicare beneficiaries as well as physicians. APMA also expressed frustration with current prior authorization policies and advocated for inclusion of APMA-proposed programs such as the comprehensive diabetic lower extremity examination (CDLEE).
Members can read all of these letters and previous years’ comments at www.apma.org/CommentLetters. If you have questions or concerns, contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.