The Trump administration is asking the public to comment on whether Medicare should overhaul how it pays physicians—potentially replacing the American Medical Association's coding system and rewarding primary care over expensive procedures. The Centers for Medicare and Medicaid Services (CMS) issued this Request for Information in its 2027 Medicare Physician Fee Schedule proposed rule on July 14, 2026, opening a 60-day public comment period that closes September 14, 2026. This is not a done deal. The request questions a payment system that has remained unchanged since Congress passed HIPAA in 1996—but any actual changes to the coding system or payment methodology would require Congressional authorization, limiting what the Trump administration can do on its own.
Official resources:
- Federal Register — Use this page to review requirements and register directly.
- Applied Policy — Use this page to review requirements and register directly.
Table of Contents
- What the Federal Government Is Questioning
- Which Doctors and Hospitals Face Payment Changes
- The Broader Overhaul the Trump Administration Is Pursuing
- How to Comment and What Happens Next
- Why the AMA's Coding System Is Controversial
What the Federal Government Is Questioning
CMS is directly challenging the American Medical Association's control of the Current Procedural Terminology (CPT) coding system, which doctors and hospitals use to bill Medicare for services. The federal government is also questioning the role of the AMA-led Relative Value Scale Update Committee (RUC) in setting physician payment policy, which determines how much each procedure or service is worth in dollar terms.
CMS is requesting recommendations on potential alternatives, including using the International Classification of Diseases, Tenth Revision, Procedure Coding System (ICD-10-PCS)—a diagnostic and procedure coding system already used worldwide—or developing entirely different methodologies for creating and valuing codes. The underlying goal is to shift Medicare's financial incentives. Instead of paying more for expensive procedures, the administration wants to reward primary care and preventive services that keep patients healthier and reduce costly complications.
Which Doctors and Hospitals Face Payment Changes
The proposed changes hit different medical specialties unevenly. Hospital-based physicians face disproportionate negative payment impacts from proposed practice expense and efficiency adjustments. Infectious disease specialists are among the hardest hit, experiencing cuts of 5% or more, while primary care physicians and preventive services receive enhanced payment incentives.
A new mandatory pilot program called the Ambulatory Specialty Model (ASM) will require certain specialists treating Medicare beneficiaries with heart failure or low back pain to participate in selected markets—shifting from voluntary to mandatory alternative payment arrangements for these conditions. This removes some doctors' ability to opt out. Independent practices and large hospital systems will respond differently to these changes, affecting how they recruit, staff, and set prices for their services.
The Broader Overhaul the Trump Administration Is Pursuing
The physician fee schedule changes are part of a wider healthcare agenda. The administration is phasing out MIPS (the Merit-based incentive Payment System), a complex reporting requirement that many doctors dislike, and expanding Accountable Care Organization participation to encourage group-based payment models.
These changes reflect administration priorities to reduce regulatory complexity and redirect Medicare dollars toward primary care and prevention. The combination creates a clear shift: doctors who focus on treating acute or complex conditions face payment pressures, while those emphasizing preventive care and chronic disease management see improved payment rates. Specialists in highly procedural fields will need to evaluate whether their practices remain economically sustainable under the new rules.
How to Comment and What Happens Next
Any physician, healthcare organization, patient advocate, health insurer, coding professional, or other stakeholder can submit written comments to CMS by September 14, 2026. The federal government will review input from all sides—some will argue the current system works well, others will push for radical change—before deciding what recommendations to send to Congress. Here's the critical limitation: implementation of changes to the CPT coding system or physician payment methodology requires Congressional authorization beyond the proposed rule stage.
CMS cannot unilaterally replace the AMA's coding system without Congress acting. What the public comment period funds is information-gathering and policy development, not immediate regulatory action. Comments can be submitted through the Federal Register at federalregister.gov. The timeline is tight: fewer than five weeks remain as of early August 2026.
Why the AMA's Coding System Is Controversial
The AMA has operated the CPT system and chaired the RUC for three decades. Critics argue this creates a conflict of interest: the AMA profits from CPT licensing fees while simultaneously voting on how much physicians should be paid for procedures that use those codes.
Defenders argue the AMA's medical expertise and broad physician input make the system legitimate and accurate. The Trump administration's willingness to question this arrangement signals openness to alternative models—but Congress, not the executive branch, ultimately decides whether to dismantle a system this entrenched.