On July 16, 2025, the Centers for Medicare and Medicaid Services (CMS) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register seeking comments on the Medicare CY 2026 Payment Policies under the Physicians Fee Schedule, Shared Savings Program Requirements, and the Prescription Drug Rebate Program (90 Fed. Reg. 32352).
The Medicare Physician Fee Schedule (PFS) is the primary mechanism by which CMS reimburses physicians and other health professionals for services provided to Medicare beneficiaries. It sets a national “conversion factor” that translates relative value units (RVUs)—based on physician work, practice expense, and malpractice costs—into payment rates. Recent trends in physician payment regulations have resulted in decreased reimbursement rates for physicians leading to economic uncertainty for independent physicians resulting in their being forced into large group practices or hospital systems.
Advocacy’s comment letter commends CMS for proposing an upward adjustment for 2026. The proposed rule provides for the following:
- For qualifying Alternative Payment Model (APM) participants (QPs), CMS proposes raising the conversion factor to $33.59, a projected 3.83% increase over the CY 2025 rate of approximately $32.35.
- For non-APM clinicians, the proposed conversion factor is $33.42, reflecting a 3.62% increase.
Advocacy often engages with small independent physicians and their representatives concerned about the downward pressure Medicare policies and uncertainties associated with reimbursement rates place on their ability to remain in private practice. In recent years, small independent physician practices have faced increasing challenges from the cumulative effects of federal regulations and administrative requirements. They are too small to employ personnel dedicated to compliance or to discovering alternative ways of navigating complex regulatory and reimbursement protocols. Providing certainty on how their reimbursement rates will be calculated will reduce some of the financial burdens with maintaining a medical practice.
COMMENT LETTER
Comments on Medicare and Medicaid Programs
(PDF, 267KB)
CONTACT:
Linwood Rayford
EMAIL:
Letters to Agencies
TAG(S):
CMS