The LTPAC Health IT Collaborative has submitted recommendations on the CY 2027 Medicare Physician Fee Schedule (PFS), encouraging CMS to ensure that long-term and post-acute care (LTPAC) providers are fully included in Medicare's value-based care and interoperability initiatives.

While supporting CMS's efforts to reduce reporting burdens, improve payment accuracy, and expand digital health capabilities, the Collaborative emphasizes that skilled nursing facilities, assisted living communities, home health agencies, hospices, PACE programs, and other LTPAC providers face unique technology and workforce challenges that must be addressed.

Key Recommendations

• Finalize payment parity for nursing facility visits regardless of whether a resident is covered under Medicare Part A or Part B.
• Strengthen interoperability by including LTPAC providers in health information exchange and value-based care models.
• Improve ACO attribution visibility so providers know a patient's ACO affiliation during care transitions.
• Recognize multiple interoperability pathways, including FHIR-based APIs and standards-based exchanges, rather than relying solely on CEHRT or QHIN participation.
• Provide targeted support for rural, small, and LTPAC-serving organizations through technical assistance, funding, and implementation flexibility.
• Expand FHIR-based data exchange and digital quality reporting pilots that include long-term and post-acute care settings.
• Preserve access to Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) by focusing safeguards on clinical accountability rather than employment relationships.
• Protect telehealth flexibilities that improve access for individuals with chronic and complex health needs.

Looking Ahead

The Collaborative believes CMS has an opportunity to advance a more connected, person-centered healthcare system. Success will require not only reducing administrative burden but also investing in the digital infrastructure that enables hospitals, physicians, ACOs, and LTPAC providers to share information, coordinate care, and improve outcomes for Medicare beneficiaries across the full continuum of care.

By pairing interoperability requirements with practical implementation support, CMS can help ensure that all providers, especially those serving the most vulnerable populations, can participate effectively in the future of value-based care.

Read the full comment letter below!