2026 MEDICARE PHYSICIAN FEE SCHEDULE (MPFS)
FINAL RULE RELEASED
Includes 2026 Quality Payment Program
2026 Conversion Factor:
$33.57 for Qualifying Alternative Payment Model (APM) participants
$33.40 for Nonqualifying APM participants
This afternoon, CMS released the CY 2026 MPFS Final Rule. CMS also released a press release, a physician fee schedule fact sheet, and a shared savings program fact sheet. The policies are effective beginning January 1, 2026.
2026 MPFS Conversion Factor
As required by MACRA statute, there are two conversion factors for CY26: a conversion factor update of +0.75% for qualifying alternative payment model (APM) participants (QP) and a conversion factor update of +0.25% for nonqualifying APM participants (or those participating in traditional MIPS). Additionally, the One Big Beautiful Bill Act of 2025 includes a 2.5% update for CY26. Therefore, the conversion factor for QPs is $33.57, while the conversion factor for nonqualifying QPs is $33.40.
The CY 2026 MPFS conversion factors of $33.57 and $33.40 represent a 3.77% and 3.26% increase from the CY 2025 MPFS conversion factor (CF) of $32.3465.
The CY 2026 finalized MPFS conversion factor reflects the following:
- Mandated updates of 0.75% for APM QPs and 0.25% for nonqualifying participants
- Mandated 2.5% update for CY26 enacted in the One Big Beautiful Bill Act of 2025
- Budget neutrality adjustment of +0.49%
The 2026 Medicare payment rate for 66984 is $462.94, an 11% decrease from the 2025 Medicare payment of $521.75. This is due to an efficiency adjustment to work RVUs and a reduction in indirect practice expense RVUs.
Efficiency Adjustment
Despite significant advocacy from ASCRS and other medical societies, CMS has finalized its proposal to apply a -2.5% efficiency adjustment to work RVUs and the corresponding intraservice portion of physician time of non-time-based services beginning in 2026. However, CMS was persuaded to exempt time-based codes, codes on the telehealth list, and new codes for CY26 from the efficiency adjustment. These codes will not be subject to the efficiency adjustment. As a result of the finalized efficiency adjustment, the work RVU for 66984 decreased from 7.35 to 7.17.
Indirect Practice Expense
CMS reiterated its assumption that there is a decline in physicians working in private practice and believes that indirect costs for PE RVUs in the facility setting at the same rate as the non-facility setting do not reflect current clinical practice. Therefore, CMS has finalized its proposal for services performed in the facility. CMS will reduce the portion of the facility PE RVUs allocated based on work RVUs to half the amount allocated to non-facility PE RVUs beginning in CY 2026. CMS acknowledges requests for exemptions for specific providers; however, they are not persuaded at this time. CMS is “interested in objective data that would help us understand and improve how indirect PE is allocated across settings of care, both in general and for specific kinds of services. We would consider such information in future rulemaking.” For CY26, the practice expense for 66984 will decrease from 8.23 to 6.16.
Medicare Telehealth Services
For CY 2026, CMS has finalized its proposal to simplify the review process for including telehealth services by removing the distinction of provisional and permanent services to the Medicare Telehealth Services List. CMS finalized its policy to limit its review to whether the service can be furnished using an interactive, two-way audio-video telecommunications system.
Direct Supervision
CMS has finalized its proposal to permanently adopt a definition of direct supervision that allows the physician or supervising practitioner to provide such supervision through real-time audio and visual interactive telecommunications (excluding audio-only). CMS finalized its proposal to exclude 10- and 90-day global services from virtual direct supervision of applicable incident-to services.
Teaching Physicians
In response to public comments regarding the extension of the current policy to allow teaching physicians to have a virtual presence for purposes of billing services furnished involving residents in all teaching settings, CMS will extend these policies for CY26.
Improving Global Surgery Payment Accuracy
In the proposed rule, CMS requested public comments on strategies to improve the accuracy and payment of global surgery payments. Specifically, CMS requested comments on procedure shares and what the procedure shares should be based on when the transfer of care modifier(s) is applied for the 90-day global packages and division of work between a surgeon and providers of post-operative care. CMS will consider these public comments for future rulemaking.
Quality Payment Program
MIPS Value Pathways (MVPs)
CMS has finalized minor modifications to the Complete Ophthalmologic Care MVP, reflecting measure changes made under traditional MIPS.
For multispecialty groups reporting via MVPs, CMS previously finalized that they must create multiple MVP subgroups as mandatory beginning in 2026. In this rule, CMS has finalized a modification to the definition and determination of a multispecialty group. Rather than being based on a two-digit specialty code, CMS will require groups self-report their specialty mix during MVP registration. Specifically, groups will report that they are single specialty if they consist of only one specialty type or of clinicians involved in a single focus of care. This means that ophthalmic groups with optometrists or non-physician advanced care practitioners will no longer be considered multi-specialty practices. In addition, CMS has finalized a policy to exempt multi-specialty small practices from the subgroup requirement.
Finally, CMS has once again reaffirmed its intention to sunset traditional MIPS and move to mandatory MVPs in the future. Though CMS has not established a sunset date yet, CMS has previously discussed using 2029 as the final MIPS performance year. ASCRS maintains that the traditional MIPS pathway should continue to be an option.
Performance Threshold
CMS will keep the performance threshold at 75 points for the 2026–2028 performance years to provide continuity and stability to MIPS clinicians.
Performance Category Weights
For the 2026 performance year/2028 payment year, the performance category weights are the following:
- 30% for the Quality performance category.
- 30% for the Cost performance category.
- 15% for the Improvement Activities performance category.
- 25% for the Promoting Interoperability performance category.
Quality
CMS will maintain a data completeness threshold of 75% for 2027 and 2028 performance periods.
Defined Topped Out Measure Benchmarks
CMS has finalized the application of the defined topped out measure benchmarks to 19 quality measures for the CY 2026 performance period. These measures belong to specialty sets and MVPs with limited measure choice and a high proportion of topped out measures, which prevents meaningful participation in MIPS.
One of the measures included is Quality ID 141: Primary Open-Angle Glaucoma (POAG): Reduction of Intraocular Pressure (IOP) by 20% OR Documentation of a Plan of Care (Medicare Part B Claims collection type only).
Relevant Measures Finalized for Removal in 2026:
- 419: Overuse of Imaging for the Evaluation of Primary Headache
- Rationale for Removal: This measure is extremely topped out.
- 487: Screening for Social Drivers of Health
- Rationale for Removal: CMS states that this process measure, as a health equity measure, will no longer be considered high-priority and that its removal aligns with removal across other CMS programs.
- 508: Adult COVID-19 Vaccination Status
- Rationale for Removal: CMS states that “outcome measures are more instrumental to improving the quality-of-care patients receive than process measures” like this one. In addition, this measure’s removal aligns with its removal across other CMS programs.
Cost
There are no new MIPS Cost measures for performance year 2026.
In a huge success for our advocacy efforts, CMS has finalized a change to the attribution methodology for the Total Per Capita Cost (TPCC) measure. Currently, all services billed by advanced practice nonphysician practitioners (NPs, PAs, and CCNSs) are classified as primary care under the TPCC. Because of this, ophthalmic groups employing NPs or PAs have been inappropriately attributed the TPCC measure, despite ophthalmologists and optometrists being excluded from the measure. Beginning with the 2026 performance year, CMS will fix this issue by excluding NPs/PAs/CCNSs from the TPCC if they are part of a clinician group where all other clinicians are excluded based on specialty.
We saw a second major win in the Cost category. CMS will now implement new cost measures on an information-only basis (not counted toward the MIPS Cost score) for two years. This will allow us to gain insight into how measures are attributed and scored and provide an opportunity to test any changes made based on any issues encountered in the first year.
Promoting Interoperability
CMS has finalized several significant changes to the MIPS Promoting Interoperability (PI) category. The following changes will begin in performance year 2026, unless otherwise specified:
- For 2025 MIPS: CMS will suppress (not score) the Electronic Case Reporting measure because of the temporary pause in onboard enacted by the CDC.
- Although the Electronic Case Reporting measure will be suppressed for 2025 MIPS scoring, CMS will require clinicians to report on the measure (attest “Yes” or “No” to meeting the requirements pertaining to Option 1 and Option 2, or claim an applicable exclusion) as the measure continues to be required.
- Security Risk Analysis (SRA) measure: CMS will add a second attestation statement to this measure. This will require clinicians to attest “Yes” to both of the following: (1) Completing an SRA, and (2) Implementing security measures to address the vulnerabilities found. This is already required under HIPAA.
- CMS adopted our recommendation that clinicians who conduct the SRA in quarter 4 of the performance year can satisfy the implementation requirement by creating a risk management plan and beginning the process of implementing the plan during the performance year.
- SAFER Guide attestation: CMS will require the use of the new 2025 SAFER Guides beginning in 2026.
- PI Bonus measures: CMS is adding a new option, “Public Health Reporting Using TEFCA.” Clinicians choosing this option will be required to attest to being in active engagement option 2 (validated data production) with a public health agency to transfer health information using TEFCA.
Improvement Activities
CMS has finalized the removal of 8 improvement activities for the 2026 performance year. These are the same activities that were suspended for 2025:
- IA_ AHE_5: MIPS Eligible Clinician Leadership in Clinical Trials or CBPR
- IA_AHE_8: Create and Implement an Anti-Racism Plan
- IA_AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols
- IA_AHE_11: Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients
- IA_AHE_12: Practice Improvements that Engage Community Resources to Address Drivers of Health
- IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B
- IA_PM_6: Use of Toolsets or Other Resources to Close Health and Health Care Inequities Across Communities
- IA_ERP_3: COVID-19 Clinical Data Reporting with or without Clinical Trial
CMS has also finalized their proposal to remove the Achieving Health Equity subcategory altogether and replace it with a new Advancing Health and Wellness subcategory.
As a reminder, there are also improvement activities that were previously finalized for removal in 2026, which include IA_CC_1 (Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop) and IA_CC_2 (Implementation of Improvements that Contribute to More Timely Communication of Test Results).
Additional Details to Come
ASCRS is carefully reviewing the final rule. The Government Relations department will be advocating for the reversal of these flawed policies in the coming months. Additional information will be detailed in upcoming editions of Washington Watch Weekly.
