The 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule has arrived, bringing with it new policy and provision changes for the coming year that will impact the healthcare landscape. As usual, the proposed rule outlines potential updates to a range of policies and provisions that govern payment for many healthcare services, including those within the Quality Payment Program (QPP), the Merit-Based Incentive Payment System (MIPS), and Advanced Alternative Payment Models (APMs). Keep in mind that these policies are still proposed and will not be finalized until the release of the final rule. While the final rule has yet to be established, professionals should stay informed about these anticipated changes, as they will influence payment, compliance, and the future of various programs.
2026 PFS Agenda and Conversion Factor Surprises
For 2026, the Trump administration is seeking to cut financial waste and improve chronic disease management for those on Medicare as chief priorities.
“For the last four years, powerful interests have targeted independent medical practices,” said U.S. Health and Human Services Secretary Robert F. Kennedy, Jr in a CMS PFS press release. “Thanks to Dr. Oz’s decisive leadership, this rule modernizes CMS payment systems, eliminates perverse incentives, and harnesses better data to improve care for patients with chronic disease while protecting the future of hometown doctors.”
Adding to the commentary, CMS Administrator Dr. Mehmet Oz explained, “We are taking meaningful steps to modernize Medicare, cut waste, and improve patient care. We’re making it easier for seniors to access preventive services, incentivizing health care providers to deliver real results, and cracking down on abuse that drives up costs. This is how we protect Medicare for the next generation while helping Americans live longer, healthier lives.”
The new year will bring a shift in policy regarding the conversion factor, as CMS establishes two separate conversion factors. This policy development stems from provisions contained in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The conversion factor for services provided by qualifying APM participants is expected to be $33.5875, representing a 0.75% annual update. For services furnished by non-APM participants, the proposed conversion factor is $33.4209, translating to a 0.25% annual update.
According to the American College of Radiology (ACR), “Both conversion factors also include a 2.5% one-year increase to the MPFS conversion factor included in the recent budget reconciliation bill, as well as a proposed 0.55% budget neutrality adjustment.”
CMS projects that radiology will see a -2% change, nuclear medicine -1%, interventional radiology 2%, and radiation oncology -1%. Ultimately, this represents a continued downward trend for payments despite efforts to offset the impacts.
Backlash and Controversy
In a news release, American Medical Association (AMA) President Bobby Mukkamala, MD underscored the problems with the methodology:
“Proposals to exclude or limit the input of expert practicing physicians and health care professionals in the development of Medicare payment policy would ultimately harm patients and represents a radical departure from the time-tested CMS decision-making process. This proposal would have negative repercussions for appropriately determining the resources required for effective patient care. To label practicing physicians conflicted when all they are doing is sharing their real-world patient experiences where empirical data often do not exist is biased, unfair and a skeptical opinion of community-based physicians.”
Dr. Mukkamala, a Flint, Michigan, otolaryngologist also commented on behalf the AMA stating, “The valuable expertise of physicians makes them an indispensable source of survey information that Medicare can count on to create payment policy. By substituting arbitrary and flawed proposals in place of front-line, real-world knowledge from expert physicians, Medicare is proposing to cut itself off from the most credible insights into the complexities of patient care, which will ultimately lead to lower-quality care, inferior health outcomes and a less sustainable Medicare system.”
For healthcare professionals and major sources of authority, there is much at stake in 2026. With many policies and changes shaping radiology in the coming year, stay tuned in to future editions for more insight into the impacts of the proposed and final 2026 PFS rules.