CMS has issued the proposed Medicare Physician Fee Schedule for Calendar Year 2026. The annually issued rule outlines proposed changes to payment rates, telehealth services, quality reporting programs, and more.
The proposed Conversion Factor is 3.62 percent with an estimated impact of 2 percent for podiatry. As required by statute, a separate conversion factor of 3.83 percent is proposed for participants in a qualifying Alternative Payment Model. Thanks to the advocacy efforts of APMA and its members, Congress provided a 2.5-percent payment increase for 2026 in the One Big Beautiful Bill.
Of additional note for our members, the proposed rule also includes the following updates:
Advocacy WIN! CMS proposes to increase the Work RVUs (wRVUs) to 28750 and 28755. The wRVU for 28750 is currently 8.57 and is proposed to increase to 8.75, and the wRVU for 28755 is currently 4.88 and proposed to increase to 6.76. These increases are a direct result of recommendations made by the AMA/Specialty Society RVS Update Committee (RUC), in which APMA is actively involved to represent our members' interests.
A Podiatry MIPS Value-Based Pathways (MVP) measure is proposed, which does not include the problematic Non-Pressure Ulcer Episode-Based Cost Measure. This MVP is reflective of APMA’s continuous engagement with CMS to provide more meaningful measures for our members, while ensuring that care is correctly attributed only to appropriate practitioners.
For CY 2026, CMS proposes 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 the non-facility setting or under the OPPS in the hospital outpatient department setting. CMS also proposes to align skin substitute categorization consistent with their FDA regulatory status, such as 361 Human Cells, Tissues, Cellular and Tissue-Based Products (HCT/P) and the device types: Pre-Market Approvals (PMAs) and 510(k)s. CMS is proposing to use a single payment rate reflecting the highest average for these three categories of skin substitute products to ensure it does not underestimate the resources involved with furnishing these services.
CMS also issued several fact sheets as part of its press release:
APMA is actively reviewing the almost 2,000-page proposed rule and will submit comments on behalf of the profession to CMS by the September 12 deadline. Contact the APMA Advocacy Department with any questions or concerns.