How to Submit Public Comments

As part of the annual Physician Fee Schedule, Medicare is exploring inclusion of a billing code (a G-code) that would reimburse the time spent counseling patients on clinical trials. 

 

Public comments are due September 14, 2026.

 

Why Your Comments Matter

This code could offset currently uncompensated provider time as well as the friction site teams absorb during recruitment and enrollment. This could also set the foundation for policy beyond Medicare. Hearing directly from clinical research sites gives policymakers crucial, real-world input to ensure the code is built practically to support sites and patients.

Medicare is currently taking public comments on this idea (due September 14). If you or your organization are interested in weighing in, we're providing an attached document which has a primer on the process and a proposed template. We think it would be meaningful hearing from research organizations as to how this can impact the industry as a whole.

Help Shape a New Medicare Code for Clinical Trial Counseling

1. Go to Regulations.gov: Use the direct comment link here or click the green button “Submit Public Comment” at the top of the Federal Register page. 
2. Fill out the appropriate information
   a. Upload or Paste: You can either copy and paste the text of your letter directly into the comment text box or upload it as a formatted file (PDFs or Word documents are standard).
   b. Identify Yourself: Fill out the required fields. If you are submitting on behalf of your practice, select "An Organization" and provide your site's name. Note: Comments are made public, so be mindful of submitting contact information you wish to remain confidential. Submitting anonymously is an option.
3. Submit: Review your entry and submit. Note that all comments (including attachments) are considered public and will be posted online. Note: Ensure your comment is submitted before the deadline on September 14, 2026.