September 11, 2025
The Infusion Providers Alliance (IPA) continues to advocate for patient access to efficient, high-quality, and cost-effective care in community-based, non-hospital settings. Today, IPA submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Calendar Year 2026 Physician Fee Schedule (PFS) Proposed Rule.
IPA’s comments focus on four issues:
- The IPA believes the “maximum fair price” (MFP) should not influence the calculation of average sales price (ASP) and strenuously objects to substituting MFP for ASP in the reported ASP file, as it would result in significant access problems to these products for commercially insured patients.
- The IPA strongly supports CMS’s proposal to make virtual direct supervision in non-facility settings permanent. This change will maintain increased access to quality care, allow for a nimble health care ecosystem in the face of future pandemics, and ensure patient adherence to vital therapies.
- The IPA supports the proposed reforms to indirect practice expense payments, which will support office-based providers, and finally provide a modest payment increase to drug administration in the physician office and infusion clinic setting.
- The IPA has concerns over the proposed revisions to the “Bona Fide Service Fee” (BFSF) definition.
Read IPA’s full comment letter to CMS here.
About the Infusion Providers Alliance
The Infusion Providers Alliance (IPA) is committed to protecting the integrity of the provider-patient relationship by empowering providers and patients to choose the most appropriate treatment together. We advocate for policies that ensure timely and adequate patient access to high quality care in IPA members’ convenient, community-based, non-hospital settings. IPA members operate over 1,000 in-office or stand-alone ambulatory infusion centers across 43 states nationwide, delivering value to the health care system and improved outcomes to patients.
All inquiries should be emailed to ewarren@infusionprovidersalliance.org.