The Medicare Physician Fee Schedule Stakeholder Submission Service

Have important feedback for CMS on the reimbursement options for 2024?

Known for our regulatory advocacy on behalf of our clients and industry, we stand ready to help you make your voice heard in this critical comment period before the Final Rule releases later this year and determines reimbursement for all of 2024.

You can submit feedback on next year's proposed reimbursement until 5:00 PM on September 11, 2023.

Digital health leaders and providers are encouraged to provide feedback directly to CMS to help them understand how their decisions impact patient care.

If you aren’t sure how to best advocate for your business, you don’t have the internal resources to meet this deadline, or you want expert guidance from attorneys who regularly advocate with regulators on behalf of their clients, then we can help.

We’re calling this fixed-fee offer the MPFS Stakeholder Submission Service, and it’s the easiest, fastest, and most compelling way for you to go to bat for your company, your clients, and your industry.

Why Submit Comments?

This public comment period is the only time CMS is legally required to read your feedback!

Every July, CMS releases a Proposed Rule with all the reimbursement frameworks they are considering implementing for the coming year. After a comment period where CMS reviews and considers ALL submitted responses, they create the Final Rule, which governs reimbursement for the following year.


All that stands between the Proposed Rule in July and the Final Rule at the end of the year is stakeholder feedback—that means you.


Without this data and ground-level perspective, CMS may not fully appreciate the value of certain technologies, the benefit to specific patient groups, or the practical use of individual services. And that oversight could negatively impact reimbursement, which ultimately affects patient care.

When you submit comments during this period, you advocate for your business, your clients, your industry, and public health in general.

Who Should Submit?

  1. Those offering a unique solution that CMS may not have considered;

  2. Those serving specific patient groups or conditions not considered for telehealth coverage;

  3. Telehealth vendors who recognize and can demonstrate the value of expanded access to telehealth services;

  4. Digital health vendors, such as RPM solution providers, who understand the value that remote monitoring of patient data adds to patient care;

  5. Those who want to add weight to the comments already submitted (like an election, more votes help your cause).

How the Service Works

Below is what you’ll get with this service:

  • A summary of all relevant potential issues for comment in the Proposed Rule;

  • Consultation with NGL to determine (i) opportunities and risks to your business related to issues presented above; and (ii) which issue(s) are most appropriate for you to comment on;

  • Draft comment letter to effectively communicate your concerns and requests to CMS;

  • Up to 2 rounds of substantive revisions of the draft comment letter; and

  • Submission of comments to CMS on your behalf (we'll share your tracking number so you can track the review process).

Because of the CMS deadline and the time we need to get this work done, you must book this service by August 18, 2023.

What You Need to Do Now

If you think you may want to submit comments, please click the button below to start the process. (Already a client? Fill out this short form, and we’ll be in touch soon!)

First, we’ll briefly discuss your goals, the timeline, and the fee. If you decide to move forward, we’ll send you an agreement and payment request.

Once you’ve paid, we’ll follow the process above. It takes about a week after the consultation for us to create those for you, and then you’ll have another week to give feedback.

Finally, we’ll submit it for you.

That’s it! We make it as easy as possible for you to advocate on behalf of your business, clients, and industry.

Whether you take us up on this offer or not, we hope you’ll take the time to submit comments to CMS so we can all look forward to more and better options for healthcare.