ASE Advocacy Update – August 2026

ASE’s member-supported advocacy efforts represent the interests of cardiovascular ultrasound professionals on legislative and regulatory issues affecting the field. Your membership, which you can renew for 2027 beginning September 1, helps ASE advocate for your profession, protect your interests, and advance policies that support echocardiography and patient care—making your continued support through annual dues essential to keeping your voice strong on Capitol Hill. In recent months, the Society has advocated for higher physician reimbursement and reduced provider burden, commented on CMS proposed rules, and provided feedback on administration policies.

Physician Payment Reform

It’s been an unusually active few months for physician payment reform, and ASE has been engaged at every stage. In April, ASE submitted a detailed response to the MACRA modernization discussion draft, responding section-by-section to the bipartisan Doctors Caucus’s MACRA overhaul and backing a full MEI-based conversion factor update along with the full budget-neutrality reform package. ASE also joined the Alliance of Specialty Medicine on a coalition letter on the MACRA modernization proposal and the broader cardiovascular community on a joint letter opposing the AUC provision in Section 205 of that draft. That advocacy fed directly into formal Congressional action: the House Ways and Means Committee favorably reported the Provider Reimbursement Stability Act (H.R. 8163) out of committee by a 44-0 vote on May 21 to raise the budget-neutrality trigger from $20 million (unchanged since 1989) to $54.3 million, and the House Energy and Commerce Health Subcommittee held its first dedicated hearing on physician payment reform in years on May 20. Momentum has continued since: Senators Boozman, Welch, and Marshall introduced a Senate companion to the Provider Reimbursement Stability Act in July, with ASE signing on as an original supporting organization.

ASE also took its case directly to the Hill, participating in the Alliance of Specialty Medicine’s Hill Day on July 21 alongside members of the ASE Advocacy Committee. ASE’s asks focused on cosponsoring and advancing Provider Reimbursement Stability Act as well as the Strengthening Medicare for Patients and Providers Act (H.R. 6160) to permanently tie physician reimbursement rate updates to inflation using the Medicare Economic Index. Additionally, ASE members advocated for utilization-management reform through the Improving Seniors’ Timely Access to Care Act (H.R.3514/S. 1816), emphasizing an echo-specific emphasis on how prior authorization delays cardiac imaging for conditions like valve disease and heart failure.

Finally, on August 21 ASE responded to the Doctors Caucus’s formal Request for Information on the Patients First Act (H.R. 9693), the bill that grew out of the MACRA discussion draft. ASE proposed extending mandatory Medicare accreditation to echocardiography labs as a fiscally responsible offset, citing MedPAC’s 2005 recommendation and Ontario’s accreditation experience, and commended sponsors for incorporating ASE’s budget-neutrality, conversion factor, and quality-reform requests into the bill as introduced. But ASE drew a firm line on Section 207, the standalone appropriate use criteria mandate carried over from the earlier draft, stating that ASE cannot support the bill’s enactment unless that provision as written is removed.

Over the last few months, ASE has engaged in comment letters, committee testimony, coalition advocacy, and direct Hill engagement to shape physician payment reform as it moves through Congress. For the full picture and ongoing updates, see ASE’s Medicare Physician Payment Reform Priority Page.

Centers of Medicare and Medicaid Services (CMS) Proposed Payment Rules

ASE has been active on the regulatory front this year, submitting comments on CMS’s IPPS, Home Health, and OPPS proposed rules on behalf of members, and is currently developing comments on the CY 2027 Medicare Physician Fee Schedule (MPFS) proposed rule. The summaries below cover what ASE asked for and how CMS responded where final rules have been issued.

Inpatient Prospective Payment System (IPPS) 
On June 5, ASE submitted comments on CMS’s FY 2027 IPPS proposed rule, touching on payment updates, MS-DRG classification, quality reporting burden, and interoperability, but the Society’s central focus was CMS’s proposal to eliminate the alternative New Technology Add-on Payment (NTAP) pathway for technologies with FDA Breakthrough Device Designation, and instead. ASE urged CMS to withdraw that proposal entirely, warning it would remove a critical bridge between FDA recognition and hospital reimbursement for emerging cardiovascular technologies. ASE shared there are currently three technologies under review through this pathway that depend heavily on echocardiographic imaging for patient selection, procedural guidance, and follow-up.

CMS finalized the FY 2027 IPPS rule on July 31 and moved forward with the repeal of the alternative NTAP pathway for FDA-designated Breakthrough Devices rather than withdrawing the proposal as ASE had asked. However, CMS pushed back the effective dates in a way that reflects ASE’s fallback request for a transition plan. The change now applies only to NTAP applications submitted on or after October 1, 2026. Technologies already approved or already under review for FY 2027 keep their existing pathway, and any device that receives Breakthrough Device designation by September 30, 2026 can still apply until FY 2029. This is a meaningful win for ASE members: it gives hospitals and manufacturers of imaging-dependent cardiovascular technologies, including the structural heart devices ASE specifically flagged, a longer runway before facing the tougher standard eligibility criteria, rather than an abrupt cutoff.

Home Health Prospective Payment System 
On August 24, ASE submitted comments on the provider-enrollment provisions in CMS’s CY 2027 Home Health proposed rule, raising concerns about four changes that could affect cardiovascular practices: making revocations retroactive by default (risking recoupment for services billed in good faith before any notice of deficiency), new denial/revocation authority tied to change-in-majority-ownership noncompliance, an expanded “managing employee” definition broad enough to sweep in medical directors and supervising physicians by title alone, and a vague “any other business or financial relationship” standard for associated-party scrutiny. This matters for ASE members because, as written, these provisions could expose echocardiography labs and cardiology practices to abrupt retroactive penalties, discourage physicians from taking on leadership roles, and disrupt beneficiary access to diagnostic imaging, all without requiring evidence of actual fraud or control. ASE asked CMS to limit retroactivity to high-risk cases, use a functional (not title-based) test for “managing employee,” require a clear nexus to misconduct before penalizing associated parties, and strengthen notice and due-process protections.

Hospital Outpatient Prospective Payment System (OPPS) 
On August 26, ASE submitted comments on CMS’s CY 2027 OPPS proposed rule, focusing on two main issues. First, ASE strongly opposed the proposal to extend the OPPS volume-control methodology to imaging-without-contrast services, including comprehensive transthoracic echocardiography (CPT 93306), furnished in excepted off-campus provider-based departments, which would cut payment by roughly 60 percent for many affected services. This is a site-neutral payment provision, a policy ASE has long advocated against, urging Congress and CMS to reject expanding site-neutral payment to echocardiography and other imaging services. In the comment letter, ASE argued that CMS has not shown this utilization growth reflects unnecessary imaging rather than patient complexity, referral patterns, or the coordinated care these departments provide, and urged CMS to withdraw the proposal or, at minimum, limit it to services with clear, service-specific evidence of inappropriate use and exempt echocardiography pending further analysis. Second, on the CY 2027 proposals for Software-as-a-Medical-Service (SaMS), ASE voiced support for CMS’s efforts to build a dedicated payment pathway for AI-enabled technologies but pressed for greater predictability, including a defined period of payment stability, assurance that SaMS payment will be additive to (not offset against) the underlying imaging service, and payment mechanisms independent of the MPFS budget-neutrality mandate so that AI-enabled tools don’t come at the expense of physician reimbursement.

Medicare Physician Fee Schedule (MPFS)  
On July 14, CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule. ASE has summarized the proposed rule and is planning to submit comments addressing the conversion factor reduction, the 2.5% efficiency adjustment, practice expense/indirect PE methodology changes, the site-of-service payment differential, duplicate testing and imaging RFI, Software as a Medical Service and AI payment policy, the Ambulatory Specialty Model, the Quality Payment Program (including the MVP mandate and lack of echocardiography quality measures), and RFIs on primary care redesign and CPT/RUC. Comments are due September 14.

Changes to the Office of Management and Budget’s (OMB) Uniform Guidance

On May 29, OMB proposed the most significant rewrite of the Uniform Guidance (2 CFR Part 200) since 2013, elevating it from non-binding direction to a binding “Uniform Grants Regulation” that would touch nearly every federal research grant. ASE reviewed the proposal and submitted formal comments urging OMB to withdraw it, and, at minimum, to preserve scientific peer review as the primary basis for funding decisions, replace the undefined “Gold Standard Science” criterion with clear operational standards, and restore open-access publication fees as allowable costs. ASE also joined three coalition responses to reinforce these points: a cardiovascular coalition letter, a research community letter, and an Alliance of Specialty Medicine letter.

Implementation is now tied up in the government funding fight. The Senate’s continuing resolution to fund the federal government includes a provision delaying the Uniform Guidance rule’s implementation through December 11, giving OMB time to review the roughly half a million public comments it received, including ASE’s, before the rule can take effect. That provision isn’t in the House-passed CR, which funds the government only through December 4 and omits the delay language, so the House must now act on the Senate’s version (or negotiate a compromise) when it returns from recess in early September.

Get Involved with ASE Advocacy!

As Congress and the Administration continue to consider policies that impact echocardiography and the health care system as a whole, it is essential to make your voice heard. Lawmakers rely on content from experts and specialists like you to shape legislation.

ASE’s new Take Action page compiles numerous resources for members to engage in advocacy:

• Guidance on contacting Congress
• Member videos on why and how to get involved
• An Advocacy Toolkit with best practices
• Links to ASE’s current policy priorities and recent correspondence.

To get started, join the ASE Advocacy Network Connect Group and share your own advocacy story with the Society.