ACR Advocates for Fair Reimbursement & Telehealth Flexibility in MPFS 2026 Proposed Rule

In July, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule, which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). Final regulations will be issued in November and, unless otherwise noted, policies will be effective on Jan. 1, 2026. The ACR provided comments on the following fee schedule provisions, among others.

Physician Reimbursement

The CMS is proposing separate updates for Qualifying Alternative Payment Model (APM) Participants (QP) and non-QP clinicians. This is the first year the CMS will implement separate conversion factors based on QP status. The CY 2026 qualifying APM conversion factor is projected to increase by $1.24, from the current $32.35 to $33.59. The CY 2026 nonqualifying APM conversion factor is projected to increase by $1.17, from $32.35 to $33.42.

The change to the conversion factors reflects the temporary one-year increase of 2.5% included in the budget reconciliation bill signed into law on July 4 by President Trump. The overall reimbursement for rheumatological services is projected to increase by 4% for 2025. The ACR urged the CMS to increase the conversion factor beyond the proposed amount to at least keep pace with the Medicare Economic Index (MEI) and to collaborate with Congress to enact a permanent inflationary update for physician payments.  

Efficiency Adjustment

The CMS is proposing a -2.5% “efficiency adjustment,” which would apply to the work Relative Value Unit (RVU) and corresponding intraservice portion of physician time of non-time-based services.

This would apply to all codes that are not based on time, such as evaluation and management (E/M) services, care management services and services on the Medicare telehealth list. The efficiency adjustment would be applied every three years, with the next applied in CY 2029, reflecting efficiency gains measured from 2027 through 2029.

Because this adjustment is not being appropriately applied and is inconsistent with fairly reflecting the time and intensity physicians use in providing thousands of services, the ACR strongly implored the CMS to rescind this proposal and explore alternatives to blunt, across-the-board efficiency adjustments that unintentionally penalize cognitive care.

Telehealth

The CMS is not proposing to extend the geographic location telehealth flexibilities that originated during the COVID-19 pandemic and were extended through Sept. 30 by Congress. Starting Oct. 1, telehealth originating-site specifications would limit patient location to certain rural and underserved areas.

The ACR encouraged the CMS to work with Congress to permanently extend all regulatory flexibilities on telemedicine reimbursement. We also called for the CMS to remove all restrictions on payment parity and remove any barriers to interstate licensure that bar providers from treating beneficiaries across state lines.