Article page with components

The Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Sept. 10, expressing ophthalmology’s concerns and providing recommendations regarding the 2026 Medicare Physician Fee Schedule proposed rule.

Developed after gathering member feedback, our comments highlight the risk of significant disruptions to practices and the downstream consequences for patient care posed by CMS’ unprecedented proposals affecting surgical services in ophthalmology.

Button 1

Button 2

Button 3

Our 28-page letter covers a broad range of issues in the proposed rule, including:

• Two conversion factors starting in 2026
• Two significant proposals for surgical care
  • Reductions to practice expense for the facility setting
  • New -2.5% efficiency adjustment to nearly all procedures
• Inaction on global surgical code payment equity
• Changes to the Quality Payment Program and Merit-Based Incentive Payment System (MIPS)

dummy data

1. Two conversion factors starting in 2026
2. Two significant proposals for surgical care
   1. Reductions to practice expense for the facility setting
   2. New -2.5% efficiency adjustment to nearly all procedures
3. Inaction on global surgical code payment equity
4. Changes to the Quality Payment Program and Merit-Based Incentive Payment System (MIPS)

We encourage members to review the document (PDF).

In addition to our formal letter, the Academy launched a multipronged advocacy campaign to fight these proposals. To amplify our message, we initiated a grassroots campaign that individual Academy and AAOE® members used to submit comments to CMS. State ophthalmology and specialty interest societies were also provided letter-writing resources to support their advocacy efforts. We greatly appreciate everyone that responded to the Academy’s call to action.  Nearly 700 individual members submitted comments to CMS.