News & Media
Approaching Deadline for 2026 Medicare Physician Fee Schedule Comments
The public comment period for the 2026 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule ends on September 12, 2025. The Michigan State Medical Society (MSMS) will be submitting comments and encourages physicians to do the same.
Some notable proposals include:
- Establishing four different conversion factors, based on whether a physician is a qualifying participant (QP) in an advanced alternative payment model (APM). The conversion factors reflect permanent and temporary updates, with QPs receiving slightly higher payments than non-QPs.
- QP: $33.5875 | Non-QP: $33.4209
- Anesthesia QP: $20.6754 | Anesthesia Non-QP: $20.5728
- Implementing new -2.5% “efficiency adjustment” would reduce work RVUs and intra-service time for non-time-based services, affecting most surgical specialties, radiology, and pathology by roughly -1%.
- Extending the G2211 add-on code to home/residence evaluation and management (E/M) services.
- Introducing optional add-on codes for Advanced Primary Care Management (APCM) behavioral health expansion.
- Sunsetting the provision that allows providers to be able to use their currently enrolled location instead of their home address when providing telehealth services from home
- Removing the flexibility of allowing teaching physicians to supervise residents virtually (via audio/video) when furnishing services in all teaching settings, except in rural training sites (limited flexibility) and in FQHCs and RHCs using real-time audio and video technology
- Maintaining the MIPS performance threshold at 75 points through the 2028 performance year to avoid harsh penalties that continue to disproportionately impact small and rural practices.
- Declining to add CPT telemedicine E/M codes to the Medicare Telehealth List.
- Redistributing indirect practice costs, leading to a -7% decrease in facility-based services and a +4% increase for non-facility-based services.
- Removing the flexibility of allowing teaching physicians to supervise residents virtually (via audio/video) when furnishing services in all teaching settings, except in rural training sites (limited flexibility) and in FQHCs and RHCs using real-time audio and video technology.
- Introducing a new mandatory Ambulatory Specialty Model (ASM) created for specialists commonly treating people with Original Medicare for heart failure or low back pain in an outpatient setting across selected regions with payment adjustments between -9% and +9%.
A detailed summary (PDF) of the 2026 Medicare Physician Payment Schedule proposed rule has been prepared by the American Medical Association (AMA). The AMA has also developed a brief summary (PDF) of two provisions in the proposed rule–the efficiency adjustment and indirect practice expenses, as well as a new RUC infographic (PDF).
Submit your comments online by September 12th. The final rule is expected by be published in November of 2025.
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