Inside the 2026 Medicare Physician Fee Schedule Final Rule
The CY 2026 MPFS Final Rule finalized dual conversion factors, a 2.5% efficiency cut to work RVUs, and new telehealth rules. Here is what it means for your practice.
CMS published the CY 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F) in early November 2025, and its provisions took effect January 1, 2026. For the first time under the MACRA framework, Medicare is paying two different conversion factors depending on whether a clinician is a Qualifying APM Participant. Layered on top is a one-year 2.5% statutory update from the One Big Beautiful Bill Act and a brand-new 2.5% efficiency adjustment to work RVUs affecting roughly 7,700 codes. If you bill Medicare Part B, this rule touches your payments starting with every claim dated January 1 or later.
What Changed
CMS finalized two conversion factors for 2026:
| Conversion Factor | 2026 Amount | Update vs. 2025 |
|---|---|---|
| Qualifying APM Participants (QPs) | $33.5675 | +0.75% |
| Non-QP clinicians | $33.4009 | +0.25% |
Both incorporate the statutory +2.5% update from Section 71202 of the One Big Beautiful Bill Act, plus a +0.49% budget-neutrality adjustment tied to work RVU changes.
The rule also finalizes a -2.5% efficiency adjustment on work RVUs for approximately 7,700 codes (down from 9,000 in the proposed rule). CMS calculated the cut by summing the last five years of Medicare Economic Index productivity adjustments. Importantly, the following categories are excluded from the efficiency adjustment:
- Time-based E/M services
- Care management and behavioral health codes
- Telehealth list services
- Maternity codes
- Drug administration
- Physical medicine, rehabilitation, and therapy
- Remote therapeutic monitoring
Individual code-level adjustments range from -9% to +9% in 2026 and are scheduled to widen to ±12% by 2033, with budget neutrality keeping the aggregate impact flat.
On the telehealth side, the originating site facility fee rose to $31.85 (from $31.01). CMS added five new services to the Medicare Telehealth Services List, removed frequency limits for subsequent inpatient, nursing facility, and critical care telehealth visits, and allowed real-time audio/video to satisfy "direct supervision" requirements. RHCs and FQHCs must now report individual HCPCS codes for Psychiatric Collaborative Care Model services and Communications Technology-Based Services (G0512 and G0071).
Telemental health in-person visit requirements were also reinstated for FQHCs and RHCs, aligning with the statutory waiver that expired September 30, 2025. Those regulatory changes took effect October 1, 2025.
Why It Matters
For most small independent practices, the headline number is modest: a 0.25% to 0.75% bump before any code-level efficiency adjustment. That is barely keeping pace with practice cost inflation. But the operational complexity is real:
- Procedural specialties absorb most of the efficiency cut. Because E/M, care management, and behavioral health codes are exempt, the -2.5% work RVU adjustment falls disproportionately on procedural codes. Specialties like dermatology, orthopedics, interventional radiology, and podiatry should expect a larger than average hit on select codes.
- QP verification becomes a monthly task. The 0.17-cent spread between $33.5675 and $33.4009 looks small, but it compounds over thousands of claims. A practice wrongly billed as non-QP gives up 0.5% of Medicare revenue.
- Telehealth billing rules shifted mid-fiscal-year. FQHCs and RHCs that relied on telemental health waivers through September 2025 now have in-person visit requirements back in force. Miss that and you are looking at denials or takebacks.
- MM14315 is the operational document. CMS Change Request 14315, with a January 5, 2026 implementation date, is where MACs are loading the new rates. If your billing software did not pick up CR 14315, your claims are pricing at stale 2025 rates.
What to Do
- Verify CR 14315 is loaded in your PM/EHR. Confirm with your vendor that MM14315 Transmittal R13507CP was applied before January 5, 2026. Pull a test batch of Medicare claims and spot-check reimbursements against the new conversion factors.
- Run a top-20 code impact analysis. Pull your highest-volume CPT codes for 2025, apply the work RVU efficiency adjustment (excluded categories get zero), and model 2026 revenue against the appropriate conversion factor. This is the single clearest way to quantify the rule.
- Confirm QP status through the QPP portal monthly. APM eligibility drives every claim. Track it deliberately rather than assuming status carries forward.
- Review your telehealth code list. Check which of your current telehealth services remain on the Medicare Telehealth Services List, and confirm the five newly added services if they apply to your specialty. FQHCs and RHCs should re-audit in-person visit documentation for telemental health patients.
- Flag efficiency-adjusted codes in your charge master. Procedural codes outside the excluded categories are the ones to watch. Build a working list so your coding team knows which codes face downward pressure and can prioritize documentation accordingly.
Talk to Us
DeltaRCM helps independent practices model the 2026 MPFS impact against real claim history, validate QP status, and catch denials from stale fee schedules. If you are unsure whether your payments are pricing correctly under CR 14315, a short conversation can identify your exposure in under a week. Contact our team for a no-cost 2026 MPFS audit.
Sources
- CMS Fact Sheet: CY 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F)
- MM14315: Medicare Physician Fee Schedule Final Rule Summary - CY 2026
- McDermott+: CMS Releases CY 2026 Physician Fee Schedule Final Rule
- Holland & Knight: CMS Releases CY 2026 Medicare Physician Fee Schedule Final Rule
- Center for Connected Health Policy: Final 2026 Physician Fee Schedule Analysis