AANEM Comments on 2026 Proposed Update to Physician Fee Schedule & QPP

Published September 18, 2025

Advocacy

On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) issued its annual proposed rule that includes updates to payment policies, payment rates and quality provisions for services furnished under the Medicare Physician Fee Schedule effective on or after Jan. 1, 2026. In response, AANEM staff drafted and submitted a 12-page comment letter addressing all pertinent aspects of the nearly 2,000-page proposed rule, emphasizing the importance of fair, predictable payments and policies that sustain patient access to specialty care. 

In the letter, AANEM acknowledged that the proposed payment increases following several years of cuts are appreciated but stressed that the changes do not keep pace with practice costs and inflation. Other major areas of concern included a proposed “efficiency adjustment” that would reduce payments for many procedures, as well as a planned overhaul of practice expense calculations that risks undercompensating facility-based services. AANEM called on CMS to base major payment changes on robust, specialty-specific data and to avoid abrupt reductions that could threaten small or independent practices.

Looking forward, AANEM remains concerned that physician payment policies are not sustainable without structural reform and continues to urge CMS and Congress to pursue permanent, inflation-based payment updates to secure long-term stability for physicians. AANEM strongly supports efforts to expand telehealth access, simplify quality reporting, and ensure flexibility for neuromuscular specialists within MIPS and QPP, and continues to advocate for quality measures and payment models that reflect the realities of subspecialty – and often consultative – care.

As always, AANEM welcomes continued dialogue with CMS, and remains committed to advocating for evidence-based, equitable payment policies. For more detail, view AANEM’s full comment letter here.


Related News