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July 15, 2025

CMS Releases Proposed CY 2026 Physician Payment Rule

  • Coding and Reimbursement

On July 14, the Centers for Medicare and Medicaid Services (CMS) released proposed payment rates for physician services for calendar year (CY) 2026. The American Academy of Audiology is conducting an in-depth review of the proposed policies to gauge the impact on audiologists. Comments on the proposals contained in this regulation are due September 15, 2025. Based on a preliminary review of the proposed rule, the Academy has identified high-level, key takeaways for audiologists.

12 New Hearing Device Service CPT Codes

Longstanding CPT® codes 92590–92595 for hearing aid services are being retired. Effective January 1, 2026, these six outdated codes—first established in 1993—will be replaced with 12 new CPT codes focused primarily on air conduction hearing devices used in the treatment of hearing loss. Audiologists will begin using this new code set to report professional services related to hearing aids and hearing devices

Learn More

Slight increase in Conversion Factor (CF)

The proposed rule includes an increase to the CF, which reflects the 2.5 percent statutory update included in the “One Big, Beautiful Bill” passed by Congress on July 3 along with a +0.55 percent budget neutrality adjustment. CMS proposes a split conversion factor for CY 2026:

  • $33.59 for clinicians in qualifying Advanced Alternative Payment Models (APMs) — a $1.24 (+3.83%) increase from the current rate.
  • $33.42 for non-qualifying APM clinicians — a $1.17 (+3.62%) increase from the current rate of $32.35.

As required by law, CMS also proposes updates to the Geographic Practice Cost Indices (GPCIs) and malpractice RVUs. These changes support CMS’s ongoing efforts to enhance efficiency, improve quality measurement, and strengthen chronic care management for Medicare beneficiaries.

Efficiency Adjustment

CMS is proposing a new efficiency adjustment to address longstanding concerns about inflated time and work values in the Physician Fee Schedule (PFS), largely based on low-response survey data from the AMA RUC. These surveys, which inform code valuations, have been criticized for subjectivity and potential conflicts of interest.

To reflect gains in clinical efficiency over time, CMS proposes applying a -2.5 percent adjustment to the work RVU and intraservice time of non-time-based services beginning in CY 2026. Time-based codes—such as E/M, care management, behavioral health, telehealth, and maternity (MMM global period) services—would be excluded.

This adjustment is based on a five-year look-back of the Medicare Economic Index (MEI) productivity factor. CMS also signals a shift toward prioritizing empirical time studies over survey-based data in future valuations and is soliciting comment on appropriate data sources.

Practice Expense

CMS is not proposing to adopt the AMA’s updated Physician Practice Information (PPI) or Clinician Practice Information (CPI) survey data for CY 2026 due to concerns with small sample sizes, low response rates, and incomplete submissions. However, CMS has modeled the impact and is seeking public comment for potential use in future rulemaking.

For CY 2026, CMS proposes significant updates to the practice expense (PE) methodology, including recognizing higher indirect costs for office-based practitioners compared to facility settings—reflecting the shift from private practice to hospital employment.

CMS also proposes incorporating routinely audited hospital cost data (e.g., from the Outpatient Prospective Payment System) to inform PE rates for select technical services, beginning with radiation treatment and remote monitoring. This aims to improve accuracy, transparency, and reduce reliance on limited survey data.

The proposed policy changes would result in payment increases for office-based (non-facility) services and reductions for hospital-based (facility) services. CMS believes these adjustments will ultimately support private practices by better aligning payment with actual resource use.

A key part of this proposal involves revising how practice expenses are calculated based on site of service, leading to notable shifts in reimbursement depending on where care is delivered.

Facility vs. Non-Facility Providers

  • Facility: Services provided in hospitals or similar settings where the facility covers overhead. Medicare pays the professional fee under the Physician Fee Schedule (PFS), while the technical component is reimbursed separately (e.g., under the Outpatient Prospective Payment System).
  • Non-Facility: Services provided in offices or clinics where the clinician incurs overhead. Medicare pays for both professional and technical components through the PFS.

Medicare Telehealth and Supervision Policy

For CY 2026, CMS proposes to eliminate provision/temporary telehealth service codes, and instead to make permanent or remove them from the list of telehealth services altogether. Reviews would focus solely on whether a service can be delivered via real-time, two-way audio-video technology.

Further, CMS is proposing to add Auditory Osseointegrated Sound Processor services, CPT codes 92622 and 92623 to the Medicare Telehealth Services List and seek publc feedback regarding this inclusion. In February, the Academy submitted a request to CMS for the inclusion of 92622 and 92623 and is pleased that CMS accepted our recommendation. CMS is not looking to make determinations to recategorize provisional codes as permanent at this time. Therefore, the following audiology services are proposed to remain on the telehealth list for CY 2026:

CY 2026 Proposed List of Medicare Telehealth Services
HCPCSShort DescriptorProposed Action
92550Tympanometry & reflex threshMaintain
92552Pure tone audiometry airMaintain
92553Audiometry air & boneMaintain
92555Speech threshold audiometryMaintain
92556Speech audiometry completeMaintain
92557Comprehensive hearing testMaintain
92563Tone decay hearing testMaintain
92565Stenger test pure toneMaintain
92567TympanometryMaintain
92568Acoustic refl threshold tstMaintain
92570Acoustic immitance testingMaintain
92587Evoked auditory test limitedMaintain
92588Evoked auditory tst completeMaintain
92601Cochlear implt f/up exam <7Maintain
92602Reprogram cochlear implt <7Maintain
92603Cochlear implt f/up exam 7/>Maintain
92604Reprogram cochlear implt 7/>Maintain

Quality Payment Program (QPP)

CMS is proposing to retain 10 measures in the designated audiology measures set. Mandated reporters must successfully report on six measures to earn a positive payment adjustment for the 2026 reporting/ 2028 payment year.

Stating that they no longer address a priority area, CMS proposes the removal of measures #487 and #498 for the 2026 performance year / 2028 payment year. Both are currently included in the audiology measures set.

  • #487 – Screening for Social Drivers of Health: Percent of patients 18 years and older screened for food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety. 
  • #498 – Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider (CSP) for at least 1 of their HRSNs within 60 days after screening. 

CMS proposes substantive changes to measures #130 and #134 (applies to electronic clinical quality measures (eCQM) collection type). Both measures are options for reporting under the designated audiology measures set.

  • #130 – Medications in the Medical Record: Percentage of visits for which the eligible clinician attests to documenting a list of current medications using all immediate resources available on the date of the encounter. 
    Proposed Change: To replace the medical reason value set with the Acute Health Crisis Direct Reference Code for the eCQM collection type, as this code better represents the intent of the denominator exception.
  • #134 – Preventive Care and Screening: Screening for Depression and Follow-Up Plan: Percentage of patients aged 12 years and older screened for depression on the date of the encounter or up to 14 days prior to the date of the encounter using an age-appropriate standardized depression screening tool AND if positive, a follow-up plan is documented on the date of or up to two days after the date of the qualifying encounter. 
    Proposed Change: A number of revisions to the guidance and numerator for the eCQM collection type to clarify that pharmacological interventions include prescribed or active depression medications. CMS proposes guidance for determining the appropriate plan of care in instances where the screening tool doesn’t adequately establish a diagnosis of depression, and how to address multiple screening results.

CMS also issued several RFIs to help support the future direction of  quality reporting.

Detailed information on these and other proposed Quality Payment Program changes is available here:  2026 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table (PDF)

CMS Medicare Physician Fee Schedule Proposed Rule and Fact Sheets

2026 Physician Fee Schedule Proposed Rule
2026 Physician Fee Schedule Proposed Rule Press Release
2026 Physician Fee Schedule Proposed Rule Fact Sheet

Payment Table:

2026 MPFS Proposed Physician Work, PE and RVU Changes
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