AAPA Urges HHS to Include PAs in Future Reimbursement Rules for Use of AI Technology
March 16, 2026
By Trevor Simon, Senior Director, Regulatory Policy
In early 2026, AAPA submitted comments to the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) regarding the topics of Artificial Intelligence and Medicare Advantage. These comments reflected both general feedback regarding these topics, as well as relevant policy obstacles faced by PAs and their patients. Below is a summary of the topics AAPA discussed in each, with links to the full letters.
Comments Regarding HHS’s Artificial Intelligence Request for Information
In AAPA’s response to the request for information, we provided comment on several aspects of Artificial Intelligence (AI). We noted several ways in which healthcare may benefit from ongoing development and adoption of AI but also identified several considerations for proper implementation.
Among these, AAPA requested that any developed language not exclude PAs from being able to utilize and be reimbursed for the use of this technology, suggested that AI implementation should align with the move to value-based care, and asserted that regulatory requirements must be established to safeguard sensitive information and ensure proper oversight of AI.
AAPA also noted several steps the department could take to bolster adoption of this technology, as well as emphasized that increased use of AI accentuated the importance of accurate attribution of services to the appropriate health professionals.
Comments Regarding the 2027 Medicare Advantage Proposed Rule
In AAPA’s comments to the rule, we supported a review of Star Ratings measures to identify those that are topped out and are overly focused on processes instead of outcomes but urged CMS to reconsider the removal of measures that capture patient experience and, where appropriate, reform measures. AAPA supported the addition of a Star Ratings measure regarding Depression Screening and Follow-Up while advocating for further behavioral health reforms and requested that CMS reconsider its removal of the Excellent Health Outcomes for All reward.
We recommended that CMS review established health equity regulatory provisions on a case-by-case basis based on whether each supports agency goals and promotes increased awareness by the agency of what services are being unused by beneficiaries and why. AAPA further supported a proposal to allow enrollees to change plans when the enrollee’s provider leaves their network, made recommendations to improve patient well-being and nutrition, and urged coordination with Congress to authorize PAs to certify the need for Medical Nutrition Therapy.
If you have any questions regarding AAPA’s comments, please contact [email protected]. For more of AAPA’s comments to CMS, HHS, and other federal agencies, visit our Communications with the Federal Executive Branch webpage.
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