CMS on July 14 released its annual proposed changes to the physician fee schedule for 2026, which will see two separate conversion factors apply, as required by statute.
Eight things to know:
1. One conversion factor will be used for qualifying alternative payment model participants and another for non-QPs. QPs are clinicians who meet thresholds for participation in advanced APMs that promote quality and cost accountability, according to CMS.
2. For 2026, CMS proposed that the QP conversion factor will increase by 0.75%, and the non-QP factor will increase by 0.25%.
3. Additional changes include a one-time 2.5% statutory increase and an estimated 0.55% adjustment for proposed changes to work relative value units. As a result, the proposed QP conversion factor will be $33.59 — a $1.24 increase (3.83%) from $32.35 — and the non-QP rate will be $33.42, up $1.17 or 3.62%.
4. The proposal also includes required updates to the geographic practice cost indices and malpractice RVUs.
5. CMS has also proposed a 2.5% cut to the work RVUs and intraservice time for non-time-based services in 2026. This cut, based on the past five years of the Medicare Economic Index productivity factor, would not apply to time-based services such as evaluation and management services, care management, behavioral health, telehealth, or maternity care, according to the agency. CMS also plans to prioritize empirical time studies over survey data in future valuations, aiming for more accurate and objective service pricing.
6. CMS is proposing to streamline how services are added to the Medicare telehealth services list by removing the distinction between provisional and permanent status. Reviews would focus only on whether a service can be provided via real-time, two-way audio-video.
7. The agency also plans to permanently remove frequency limits on subsequent inpatient visits, nursing facility visits and critical care consults.
8. Finally, CMS proposes ending the temporary policy that allows teaching physicians to supervise residents virtually in all settings. Beginning in 2026, the previous rule would return — requiring in-person presence during key parts of care in metropolitan areas, while keeping the rural exception.
Click here to view the full 1,803-page proposed rule.
