By: Sara Hussey, MBA, CAE – ACMS Executive Director (with contributions from the AMA)
The Centers for Medicare & Medicaid Services (CMS) has released the CY 2026 Medicare Physician Fee Schedule proposed rule (CMS-1832-P), and now is the time for physicians to weigh in. CMS is accepting comments until Friday, September 12, 2025.
The American Medical Association (AMA) has prepared a comprehensive draft comment letter addressing the proposed changes. We strongly encourage ACMS members to submit comments.
Why This Matters
Medicare physician payment continues to fall behind the real costs of running a practice. Between 2001 and 2025, physician pay was essentially flat, while practice costs rose 59%—a 33% decline after inflation. Without meaningful reform, access to care for seniors and sustainability for practices are at risk.
Key proposals in the rule include:
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Conversion factor updates that are positive but still insufficient without permanent, inflation-based adjustments.
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A proposed 2.5% “efficiency adjustment” cutting work RVUs across more than 7,000 services—despite new data showing that operative times are not decreasing.
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Changes to practice expense methodology that could further disadvantage independent practices compared to hospitals.
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Updates to the Merit-based Incentive Payment System (MIPS)—some responsive to AMA input, but still leaving physicians burdened with red tape.
Specialty-specific analyses from the AMA show that under CMS’ proposals, many physicians would face significant cuts—for example, 37% of oncologists, 56% of internists, and 80% of infectious disease physicians.
Documents:
Estimated Specialty Impact of CY 2026 MFS Proposed Rule
PE High Cost Supplies ($500) Analysis for 2026
RUC Recommendations on Modifications to Visits in Global Period – NPRM for 2026
Time-Based Codes Subject to Efficiency Adjustment in Error
How You Can Act
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Review the AMA’s draft letter and attachments (linked above).
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Draft your comment to CMS by highlighting:
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How these proposed cuts would affect your practice and patients.
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Optional: Your support for the AMA’s recommendations (e.g., replacing across-the-board efficiency cuts with data-driven adjustments, ensuring inflation-based updates, and reducing MIPS burden).
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Submit your comment by September 12 through Regulations.gov.
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Use 1 of the 3 following ways to officially submit your comments:
- Electronically: regulations.gov
- Regular mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1807-P, P.O. Box 8016, Baltimore, MD 21244-8016.
- Express or overnight mail: 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.
Why Your Comment Matters
Every physician voice adds weight. CMS takes note not only of national organizations like the AMA, but also of individual physician comments that bring local context and real-world impact. Whether you are in solo practice, part of a group, or hospital-based, your perspective helps shape the final rule.
Take Action Today: Add your voice, stand with your colleagues, and help protect the future of physician practice in Medicare.