CMS Releases Proposed Updates to Physician Fee Schedule and the Quality Payment Program
Published July 30, 2025
Advocacy
On July 14, the Centers for Medicare & Medicaid Services (CMS) issued the 2026 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule. AANEM staff are reviewing the nearly 2,000-page rule, but key highlights so far include:
Conversion Factor Updates
• CMS proposed two new conversion factors for 2026 that will affect AANEM members (as well as two new anesthesia conversion factors) as required by the Medicare Access and CHIP Reauthorization Act (MACRA).
o $33.5875 (an increase of 3.8% from $32.3465) for qualifying participants (QP) in advanced alternative payment models (APM)
o $33.4209 (an increase of 3.3% from $32.3465) for all other physicians, including those in MIPS
• Both reflect a temporary, one-year 2.5% update enacted in H.R.1, the One Big Beautiful Bill Act and a .55% budget neutrality adjustment.
Efficiency Adjustment
• CMS proposes a new a -2.5% efficiency adjustment to certain RVUs, primarily affecting surgical specialties, radiology and pathology, resulting in a reduction of overall payment by about 1%.
Indirect Practice Expense (PE) Calculations
• CMS proposes shifting indirect PE calculations, reducing payments to facility-based services by -7% and increasing non-facility payments by 4%.
Merit-based Incentive Payment System (MIPS)
• CMS proposes maintaining the 75-point MIPS performance threshold to avoid a MIPS penalty through the CY 2028 performance year/2030 MIPS payment year.
Other Updates to Note
• CMS did not propose a correction to prior overestimated utilization of the office visit add-on code, G2211, which contributed to a substantial cut to the 2024 conversion factor due to budget neutrality requirements.
• CMS does not intend to add the new in 2025 CPT telemedicine E/M codes to the Medicare Telehealth List for 2026.
AANEM staff will continue reviewing the rule and will draft a comment letter in coordination with the AANEM Board of Directors. Once finalized, a summary and link to the letter will be shared via Spark. If you have questions or concerns about the proposed rule, you can email the policy department at policy@aanem.org.