Medicare Physician Fee Schedule Comments Due September 12

The Centers for Medicare & Medicaid Services (CMS) is accepting comments regarding the Medicare Physician Fee Schedule (MPFS) 2026 proposed rule until September 12, 2025. 

The MPFS 2026 proposed rule was published in the Federal Register on July 16, 2025, and proposes numerous updates and revisions to Medicare payment policies, including:

• Updates to MPFS payment rates
• New billing codes with lower time thresholds for remote physiological monitoring (RPM) and remote therapeutic monitoring (RTM) services
• New behavioral health integration (BHI) add-on billing codes for advanced primary care management (APCM)
• Expansion of digital mental health treatment (DMHT) medical device payment codes to cover treatment for attention deficit hyperactivity disorder (ADHD)
• Revised billing standards and rates for skin substitutes
• Telehealth revisions
• Permanently allowing virtual direct supervision through audio/video real-time communications technology
• The Ambulatory Specialty Model (ASM), a new alternative payment model that would start in 2027 and would be mandatory for individual clinicians who are assigned a specialty code of cardiology on the plurality of their Medicare Part B claims (with respect to the heart failure cohort) or a specialty code of anesthesiology, interventional pain management, neurosurgery, orthopedic surgery, pain management, or physical medicine and rehabilitation on the plurality of their Medicare Part B claims. (for the lower back pain cohort) who meet ASM participant eligibility criteria
• Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) revisions
• Medicare Shared Savings Program (MSSP) revisions
• Medicare Diabetes Prevention Program Expanded Model (MDPP) changes.

For a summary, see CMS Fact Sheet.

  

CMS is requesting information on various topics, including:

• Payment structures for software as a service (SaaS) and AI
• Prevention and management of chronic disease
• Potential coding and payment for medical devices
• Global surgical packages
• Approaches and opportunities to streamline regulations and reduce burdens on providers participating in the Medicare program

  

Comments can be submitted electronically by September 12, 2025, here. Public comments on the proposed rule can also be viewed. 

For more information on the MPFS 2026 proposed rule or related issues, please contact McDonald Hopkins' Healthcare attorney, Rick Hindmand.