ASA Urges CMS to Expand Medicare Advantage Network Adequacy Standards to Include Anesthesiology

Earlier this week, the American Society of Anesthesiologists (ASA) submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Contract Year 2027 Medicare Advantage and Medicare Prescription Drug Benefit Program Proposed Rule, focusing on network adequacy requirements under 42 CFR §422.116.

ASA expressed concern that anesthesiologists and pain medicine specialists are not explicitly identified as provider specialty types subject to these standards. While anesthesiology has historically been treated as a facility-based service, shifts in care delivery toward outpatient and ambulatory settings make this approach increasingly insufficient. Anesthesia and pain management services are now routinely provided in ambulatory surgical centers and hospital outpatient departments, underscoring the need for explicit recognition.

ASA warned that the lack of clear network adequacy requirements has coincided with troubling trends among Medicare Advantage plans, including exclusion of anesthesiologists and forcing unfair contract terms. ASA raised concerns that some plans may be leveraging the No Surprises Act to pressure physicians into accepting lower payment rates or face exclusion from networks. These practices risk undermining patient access to essential anesthesia and pain management care.

CMS has an opportunity to address these issues by clarifying and strengthening network adequacy requirements. ASA strongly recommends that CMS revise §422.116(b)(1) to explicitly include anesthesiology and pain management as provider specialty types. ASA further urges CMS to establish appropriate physician-to-patient ratios and implement robust enforcement mechanisms to ensure timely and reliable access to care for Medicare Advantage enrollees. 

Contact ASA Department of Payment and Practice Management at ppm@asahq.org for further information.