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Highlights of NASW’s Comments on the 2027 Proposed Physician Fee Schedule

September 21 2026

NASW ‘s Practice Team reviewed the 2027 Medicare Physician Fee Schedule proposed rule and submitted comments to the Centers for Medicare & Medicaid Services (CMS) addressing numerous topics that may impact social workers, other healthcare providers, and beneficiaries. 

The full comment letter has been posted to NASW’s website and can be found here: NASW Submits Comments on the Proposed Medicare Physician Fee Schedule for Calendar Year 2027. NASW advocated for each of the following:

Telehealth Flexibilities

  • Permanent Adoption: supported delaying the in-person visit requirements for mental health services provided through telehealth and extending audio-only flexibilities. NASW strongly urged CMS to make all telehealth flexibilities for mental health services permanent. 
  • New Telehealth Codes: supported adding Advance Care Planning (ACP) Healthcare Common Procedure Coding System (HCPCS) codes GACP1 and GACP2 and Shared Medical Appointment codes to Medicare’s telehealth services list.

Scope, Recognition, and Payment for Services Provided by Clinical Social Workers (CSWs)

  • Rate Increase: advocated for increased reimbursement for CSWs, who are currently reimbursed at only 75 percent of the Medicare PFS, a rate lower than the 100 percent paid to psychiatrists and psychologists and the 85 percent received by other nonphysician practitioners. 
  • CSWs in Skilled Nursing Facilities (SNFs): urged CMS to allow beneficiaries who receive SNF services under Medicare Part A to access mental health services provided by independent CSWs under Medicare Part B.
  • Smoking and Tobacco Use Cessation; Screening, Brief Intervention, and Referral to Treatment (SBIRT): supported increased valuation for smoking and tobacco use cessation (Current Procedural Terminology [CPT] codes 99406 and 99407) and for SBIRT services (HCPCS codes G2011, G0396, and G0397).
  • Psychiatric Collaborative Care Management (CoCM): supported CMS’s proposal to increase the labor rate for services provided by behavioral health care managers (which include CSWs). 
  • Care Management: urged CMS to provide incentives for primary care practices to engage social workers as auxiliary personnel in the provision of care management services and encouraged CMS to enable CSWs to provide and bill for care management services independently within primary care practices.
  • ACP Services: supported CMS’s proposal to create new HCPCS G-codes GACP1 and GACP2 to reflect service delivery by various members of the interdisciplinary team (IDT) and urged CMS to allow CSWs to independently furnish and bill Medicare for ACP services.
  • Shared Medical Appointments (SMAs): supported CMS’s proposal to establish a coding and payment pathway for SMAs, provided feedback on SMA design and beneficiary consent, and advocated for CSWs to play a primary role on SMA interdisciplinary teams (including allowing CSWs to serve as the billing practitioner when the primary focus of the appointment is on mental or behavioral health). 

Coding and Interdisciplinary Care Delivery

  • CPT Process: supported the established CPT coding process as a single national coding vocabulary system that is clear and helpful for CSWs. 
  • Community-Based Palliative Care: supported Medicare reimbursement for a community-based approach to palliative services, urged all palliative care IDTs to include at least one social worker (as defined in the 2026 NASW Practice Standards for Serious Illness Care: Hospice and Palliative Social Work), urged CMS to authorize Medicare reimbursement for a palliative care consultation for any beneficiary, and advocated for eligibility to be based on a beneficiary’s overall needs regardless of the person’s life expectancy.
  • Intensive Lifestyle Interventions (ILIs) to Slow Progression of Alzheimer’s Disease or Related Dementias (ADRD): provided input on domains to incorporate various domains within ILIs, recommended flexibility in ILI eligibility and frequency, and urged CMS to require inclusion of a social worker in each IDT that provides ADRD ILIs.

Use of Artificial Intelligence in Practice

  • Clinician Use of Artificial Intelligence (AI) to Improve Beneficiary Care: acknowledged growing AI use among social workers but emphasized that more time was needed to evaluate best practice, address privacy and security concerns, and assess workforce readiness before CMS begins incentivizing the use of this emerging technology as part of the Quality Payment Program.
  • Technology and AI Use in Primary Care: urged CMS to proceed cautiously, focusing on robust information gathering, monitoring, and evaluation rather than on Medicare incorporation of and payment for AI.

Medicare Eligibility

  • Limiting Medicare Coverage of Immigrants: strongly opposed Congressionally mandated changes that terminates Medicare coverage and limits Medicare eligibility for many groups of immigrants residing lawfully in the United States, urged CMS to bolster its proposed processes to notify enrolled beneficiaries of Medicare termination, and recommended increased flexibility for qualified immigrants to enroll or re-enroll in Medicare. 

Conclusion

CMS plans to release the 2027 proposed Physician Fee Schedule final rule in November 2026. In early 2027, the NASW Practice Team will publish a summary of social work–related topics within the final rule.