Breaking Down the CMS 2026 Proposed Rule

Aug 5, 2025

CMS Releases 2026 Proposed Physician Fee Schedule: Key Takeaways for Providers

On July 14, 2025, CMS released the 2026 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule, outlining major updates to MIPS, APMs, and introducing a new mandatory payment model.

These changes could significantly affect reimbursement, reporting, and value-based care participation. Staying informed is essential to protect your practice’s financial health and compliance.

NPRM KEY CHANGES

• • MIPS MVPs and APP Enhancements: CMS proposes notable updates to the Merit-based Incentive Payment System, focusing on MIPS Value Pathways (MVPs) and the Alternative Payment Model Performance Pathway (APP). These changes will affect how you report quality, cost, and improvement activities. Ultimately, these changes will impact your payment adjustments. Understanding the details is key to maximizing performance and avoid penalties.
  • Shared Savings and Advanced APM Updates: CMS is proposing changes to the Shared Savings Program and the Advanced APM Track that may impact ACO eligibility, financial reconciliation, and the incentives.
  • New Mandatory Payment Model: CMS is introducing a MANDATORY payment model for ambulatory specialists treating Original Medicare patients with heart failure and low back pain. This shift toward condition-specific value-based care could significantly impact both reimbursement and care strategies for affected practices.

   

  RESOURCES LINKED BELOW:

  NPRM Proposed Rule: Federal Register 2026 Proposed Rule
  PFS Fact Sheet: Calendar Year (CY) 2026 Medicare Physician Fee Schedule Proposed Rule | CMS
  QPP Fact Sheet: 2026 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table
  MSSP Fact Sheet: Calendar Year (CY) 2026 Medicare Physician Fee Schedule Proposed Rule — Medicare Shared Savings Program Proposals | CMS

  Comments MUST be submitted by 5 PM EDT September 12, 2025, in one of the following three ways (choose only one of the ways listed). Refer to File Code CMS-1832-P with your submission.

  • • • Electronically: Submit electronic comments on this regulation HERE. Follow the “Submit a comment” instructions.
      • By regular mail: Mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, P.O. Box 8016, Baltimore, MD 21244-8016. Allow sufficient time for mailed comments to be received before the close of the comment period.
      • By express or overnight mail: Send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.

      Contact YOUR experts at Kentucky REC with all your Quality Payment Program questions. We’re here to help: 859-323-3090.