MMA Comments on Proposed 2026 Medicare Physician Fee Schedule

September 18, 2025

On September 12, the MMA submitted a formal comment to the Centers of Medicare and Medicaid Services (CMS) on the proposed rule for the 2026 Medicare Physician Fee Schedule (MPFS).  

The letter includes calls to action on the following provisions: 

1. Conversion Factors. The proposed rule includes a congressionally approved 0.25% to 0.75% permanent increase, and a 2.5% temporary, one-year increase in the 2026 conversion factors (i.e., dollar multipliers used to determine Medicare payments to providers). In its comment, the MMA stresses that these increases do not sufficiently account for increasing practice costs, citing that “Medicare payments to physicians have declined by 33% since 2001, based on…data reported by CMS.” The MMA urged CMS to work with the Trump Administration and Congress to implement permanent, inflation-based updates to Medicare physician payments. 

2. Proposed Efficiency Adjustment. The proposed rule includes a 2.5% decrease in the work relative value units (i.e., RVUs, service-specific payment weights) for more than 7,000 non-time-based services. CMS argues that this decrease accounts for, what they propose to be, increased physician efficiencies in providing non-time-based services over time. In its comment, the MMA values CMS’ commitment to ensuring payments account for changes in practice efficiencies but urges CMS to do so “deliberately, using quantitative evidence corroborated by physician input.” The MMA highlights that “at least one study of over 1.7 million surgeries between 2019 and 2023 suggests that the CMS proposed efficiency adjustment may not be supported by empirical surgical time data (Childers et al., 2025).” 

3. Site of Service Payment Differential. The proposed rule includes a 7% decrease in physician payment for facility-based services and a 4% increase in physician payment for non-facility-based services. CMS argues that these adjustments are intended to address the competitive disadvantages experienced by independent/private practice physicians, relative to outpatient hospital departments. In its comment, the MMA appreciates CMS’ interest in narrowing this pay differential, but asks CMS to consider how the proposed rule might fail to address the root cause(s) of the pay differential and lead to adverse consequences. Specifically, the MMA emphasizes that the pay differential is at least partially attributable to the  fact that, “while a private practice physician’s income is limited to billable physician services (that do not receive annual, inflation-based updates in Medicare payments), an employed physician’s income is determined by the hospital’s total revenue, inclusive of physician and hospital services.” Moreover, the proposed rule might lead to further consolidation, since many private practice physicians necessarily provide some services in outpatient departments or ambulatory surgery centers.  

The MMA is committed to continuing its fight for evidence-based, lasting Medicare reforms that appropriately compensate physicians for their work. For more information, contact Adrian Uphoff, manager of health policy & regulatory affairs.