The National Produce Prescription Collaborative Response to the CY2026 Medicare Physician Fee Schedule Proposed Rule

Today, the NPPC submitted a response to the CY2026 Medicare Physician Fee Schedule proposed rule. Here is an excerpt from the letter:
 
“…we believe PRx should be considered alongside the MTM as a service that should be covered under Medicare Part B. Providers across the country are already issuing PRx. Modernization in technology has enabled both restricted-spend purchase cards, which can be used at the national networks of food retailers, as well as high quality produce box deliveries, to nearly every address in the United States. The research and findings on PRx are the most voluminous of the three food prescription interventions (i.e., PRx, MTM, MTG), providing a robust evidence source for the benefit and cost savings of this intervention. As a result, both patients and providers support efforts to expand the reach of PRx in healthcare.

The NPPC also wishes to express support for the MTM benefit in Medicare. As longtime advocates for this intervention, we strongly support the Food Is Medicine Coalition (FIMC)’s technical comment on the MTM questions stated in the comment. We believe that CMS should create separate coding and payment for MTMs as an incident-to service. Such a change would both reflect current evidence of impact and address a critical gap in access to medically tailored nutrition in the Medicare program. We agree with the points raised in FIMC’s submission and believe their comment accurately reflects the views of the NPPC. We respectfully urge the agency to give full consideration to the recommendations outlined in FIMC’s comment. 

However, we also encourage CMS to consider PRx to be a prescribable benefit under clinician-determined medical necessity. In this comment we provide an explanation for why and how a PRx benefit should be considered under the same incident-to framework.”

Click here to read the full comment

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