CAP Submits Comments on Proposed 2027 Medicare Physician Fee Schedule

The College of American Pathologists (CAP) submitted comments to the proposed 2027 Medicare Physician Fee Schedule (PFS), addressing proposals that the organization claims could adversely affect laboratory medicine.

In a Sept. 14 letter, CAP urged CMS to not remove Software as a Medical Service laboratory analyses that are performed on laboratory tests from the Clinical Laboratory Fee Schedule to the PFS. CAP recommended that CMS work with stakeholders to develop a dedicated payment framework with a budget separate from the PFS that avoids inappropriate effects on physician payment.

Additionally, in a request for information regarding use of Current Procedural Terminology (CPT) as the national coding standard for health care professional services, CAP affirmed its support of CPT “as a uniform, clinically grounded, and continuously maintained system for describing health care services across payers and settings.” CAP encouraged CMS to work with the American Medical Association and medical specialty societies to assess and improve the existing CPT framework.

Source:

https://www.cap.org/wp-content/uploads/2026/09/CY-2027-PFS-Proposed-Rule-Comment-Letter_CAP.pdf?download=true