In September 2025, the Center responded to an annual proposed rule from the Centers for Medicare and Medicaid Services (CMS) that governs how our nation’s largest payer—the federal government—pays for physician services under the Medicare program.  

The work of the Peterson Health Technology Institute gives us unique insights into the critical questions that CMS is grappling with in the CY 2026 Medicare Physician Fee Schedule. The Center focused comments on the coding and valuation of remote monitoring services, updates to payment for digital mental health treatment, and the new ambulatory specialty model, highlighting that CMS should: 

• Base reimbursement for remote monitoring codes on their clinical value, rather than physician work time or equipment expense, and develop evidence-based, condition-specific duration limits for these services.  

• Broaden Medicare coverage for digital mental health technologies. Based on PHTI’s review of virtual solutions for mild to moderate depression and anxiety, these tools are clinically effective and should be covered by Medicare. Payment rates should be tied to clinical value, and PHTI’s budget impact models could inform appropriate reimbursement amounts.  

• Publish a list of preferred, high-value digital tools that would support treatment for low back pain and heart failure in the new Ambulatory Specialty Model based on PHTI’s evaluations of virtual musculoskeletal solutions and digital hypertension management solutions.