PAN Foundation submits comments on 2026 payment policies rule
Information about this website: Following the March 2026 merger of Patient Advocate Foundation and the PAN Foundation, this website is now a part of Patient Advocate Foundation and remains active during our website transition.
Where to find information during our transition:
- About the merged organization: uniting.patientadvocate.org
- Financial assistance: totalassist.org
- Additional direct patient services and resources: patientadvocate.org
- Education: panfoundation.org and education.patientadvocate.org
- Clinical trials education: clinicaltrials.panfoundation.org
- Advocacy: npaf.org
- Research: patientinsightinstitute.org
The PAN Foundation submitted a letter to the Centers for Medicare and Medicaid Services Administrator with comments on the CMS 2026 Physician Fee Schedule Proposed Rule, which addresses telehealth services, medically necessary dental health services, and patient and provider education about policies.
PAN supports CMS’s proposal to streamline the Medicare Telehealth Services List review process and eliminate the distinction between “provisional” and “permanent” telehealth services, and removing outdated evidentiary hurdles, such as requiring peer-reviewed literature for low-utilization services. PAN also encourages the agency to continue advancing policies that support permanent telehealth access.
PAN encourages the agency’s ongoing work to clarify and implement “inextricably linked” oral health coverage in Medicare. The letter expresses disappointment by the agency’s decision to not identify additional examples of clinical scenarios in which payment for dental services is appropriate. PAN respectfully encourages CMS to consider the following suggestions to advance implementation of the payment rule so that beneficiaries can access covered care:
- Outreach to relevant providers
- Transparency and access to contractor pricing information
- Clear and accurate contractor-level information and assistance
- Allow more immediate revocation of opt-out status
- Oversight of dental payment by Medicare Advantage plans
- Facilitating provision of “inextricably linked” care by in-network dentists
PAN supports the agency’s proposal to adopt a new improvement activity – Integrating Oral Health Care in Primary Care – to the inventory of activities that MIPS eligible clinicians can engage in to improve clinical practice or care delivery. In many communities, particularly urban and rural underserved communities, primary care clinicians play the key role in caring for people with chronic and serious illnesses. This underscores the need to integrate dental assessment, education, and referrals into primary care delivery.