In its calendar year (CY) 2026 physician fee schedule (PFS) proposed rule, the Centers for Medicare & Medicaid Services (CMS) proposes several changes that could impact today’s medical practices and billing companies. In this article, we’ll provide an overview of those changes and the important topics on which physicians — and their billers — may want to share comments. 

Comments on the CY 2026 physician fee schedule proposed rule are due September 12, 2025, and you can submit them through this link. Not sure how to write an effective or persuasive comment on a federal regulation? Check out this guidance. 

Dr. Soma Mandal, MD, internal medicine specialist, explains: “The CY 2026 Physician Fee Schedule proposed rule introduces significant changes that will shape the future of medical practice operations, reimbursement, and patient care delivery. Physician input is essential to ensure that these policies support clinical excellence, financial sustainability, and access to high-quality care.” 

CMS proposal: In its CY 2026 physician fee schedule proposed rule, CMS proposes a 3.8% payment increase for physicians in alternative payment models (APM) and a 3.3% increase for those in non-APMs payment models. 

However, medical billing expert Terri Joy, BSHCA, MBA, CPC-1, notes there is usually a difference in the proposed payment increases and the final versions.

Opportunities for comments: Describe how these updates might affect your medical practice, including its budget, hiring, patient access, revenue, and more.

CMS proposes a -2.5% efficiency adjustment for certain non-time-based services the agency expects will accrue efficiencies over time as changes in medical practice occur, including changes in clinician expertise, workflows, and technology. 

Joy says it's important to consider "there is always some change to the efficiency adjustment by the time the new year rolls around."

The agency also proposed a controversial shift: moving away from American Medical Association (AMA) survey data when setting RVUs and pricing. Its current payment methodology relies on the AMA’s Physician Practice Information (PPI) Survey data.

CMS expressed concerns about the survey's low physician response rates, and incomplete data. It also noted research that physicians may be overinflating the time assumptions built into the valuation of many PFS services.

This indicates CMS’ intent to transition away from the AMA Relative Value Scale Update Committee (RUC) process.

"This is a paradigm shift that could affect the entire insurance industry," Joy states.

Opportunities for comments: Submit any empirical data (e.g., electronic health record logs, operating room logs, and time-motion data) you have. Also, consider commenting on:

CMS is considering creating a new place of service (POS) code for “enhanced” urgent care centers — those that offer extended hours and expanded diagnostic and therapeutic services beyond typical urgent care. The agency is also exploring an add-on G-code to account for the additional resources needed when providing care in these settings. 

If you're a medical billing company, make sure to look for the new POS code. If you bill for any potential enhanced urgent care centers, include the changes in your CY 2026 budget projections.

Opportunities for comments: CMS is seeking feedback on how best to define these enhanced centers, and on the proposed add-on code valuation.

CMS proposal: CMS proposes removing the “provisional” telehealth distinction so that all services on the Medicare Telehealth Services list are considered permanent. In addition, the agency proposes adding the following services to the Medicare Telehealth Services list for CY 2026:

It proposes to delete social determinants of health risk assessment (G0136) from the Medicare Telehealth Services list for CY 2026.

CMS also proposes permanently allowing Rural Health Clinics (RHCs) to meet direct supervision requirements for certain services and supplies through real-time audio and visual interactive telecommunications (excluding audio-only). 

The agency would also continue to allow RHCs to bill for non-behavioral health visits furnished via telecommunication technology by reporting HCPCS code G2025 — including services furnished using audio-only communications technology — through December 31, 2026.

CMS declined a request to add certain telemedicine evaluation and management (E/M) codes (CPT 98000–98015) to the Medicare Telehealth Services list, noting they are not separately payable under the Physician Fee Schedule (PFS). 

The agency is, however, proposing to permanently remove frequency limits for select services — including Subsequent Inpatient Visits, Subsequent Nursing Facility Visits, and Critical Care Consultations — building on the expansions finalized in the CY 2025 PFS rule.

Opportunities for comments: Share your thoughts on how a more streamlined process for adding services to the Medicare Telehealth Services list might benefit your medical practice. Also, provide safety/quality data supporting virtual supervision in your setting and identify any services for which you think virtual supervision may not be appropriate.

In the proposed rule, CMS wants to create 3 optional add-on codes for Advanced Primary Care Management (APCM) services that would facilitate providing complementary behavioral health integration (BHI) or psychiatric Collaborative Care Model (CoCM) services:

It also proposes these services to be billed as add-ons when the APCM base code is reported by the same practitioner in the same month. In addition, it proposes expanding coverage for digital mental health treatment devices for ADHD. 

Opportunities for comments: Comment on how the new add-on G-codes might affect workflow, staffing, and patient outcomes. Also, share comments on how establishing payment policies for other digital therapy devices might be helpful.

CMS proposes grouping similar products or services into a single billing code and using a single payment amount for reimbursement. It is also proposing to pay for skin substitute products as incident-to supplies when they are used as part of a covered application procedure paid under the PFS in a non-facility setting.

Opportunities for comments: Comment on whether you think these changes might lead physicians to choose products supported by strong clinical evidence and competitive pricing, reduce administrative burden, and promote decision-making centered on patient care. Consider providing specific insights into stocking implications and the potential for underpayments.

CMS proposal: In its CY 2026 physician fee schedule proposed rule, CMS proposes the following remote patient monitoring updates effective January 1, 2026:

Opportunities for comments: Comment on whether you think these time intervals capture typical patient scenarios and estimate how often patients exceed or fail to meet monitoring thresholds. 

The CPT Editorial Panel created 3 new time-based codes (90XX1–90XX3) for vaccine counseling when no vaccine is administered. These replace several older Medicaid HCPCS codes (G0310–G0313) previously used for stand-alone vaccine counseling.

CMS proposes to assign these new CPT codes a status indicator of “I” (not valid for Medicare purposes) because Medicare already uses other codes for vaccine counseling. No work or practice expense RVUs are being proposed for these codes.

Opportunities for comments: Share whether you believe the new CPT codes (90XX1–90XX3) for immunization counseling should be recognized under Medicare and, if so, suggest how they could be valued appropriately.

CMS expanded reporting requirements for modifier -54 (“surgical care only”) starting January 1, 2025. Surgeons must now report modifier -54 whenever they perform only the procedure portion of a global surgical package and do not provide post-operative care — not just when a formal transfer of care is documented.

Additionally, CMS finalized a new add-on code (G0559) to better reflect the time and resources involved when post-op care is provided by a different practitioner than the one who performed the surgery.

CMS is seeking public comments on: 

CMS is also proposing a number of targeted coding and payment changes, including:

When crafting a comment on the CY 2026 physician fee schedule proposed rule, be sure to include the following when you have it and when relevant:

In the meantime, stay tuned for a final rule later this fall set to take effect January 1, 2026.

Learn how Tebra's all-in-one practice management and billing platform can help your medical practice navigate the CY 2026 physician fee schedule changes with intelligent automation, real-time claims tracking, and integrated workflow solutions that reduce administrative burden while maximizing reimbursements. Book a free, personalized demo today.