Academy Submits Comments on Proposed Revisions to MPFS CY 2026

In response to the Centers for Medicare and Medicaid Services (CMS) Notice of Proposed Rulemaking (NPRM) regarding revisions to Medicare payment policies under the Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2026, the Academy submitted public comments regarding policies that could have an impact on audiologists. The annual process includes the publication of the proposed rule in July, the deadline for public comment in September, CMS review of the comments and adjustments, if any, to the policies, and the publication by November of the final rule for implementation on January 1.

For CY 2026, the Academy noted some substantive policy changes for audiologists. Of ongoing concern are the Medicare conversion factor (CF), the proposed efficiency adjustment, and updates to the practice expense methodology. While the Academy supports the first proposed increase in the CF over the last five years, we urge CMS to establish long-term payment reform that includes meaningful increases to reflect a cost-of-living adjustment and address inflationary pressures on clinical care. The Academy also opposes the proposed, arbitrary efficiency adjustment that would reduce RVUs by 2.5 percent every three years and be applied to several audiology time-based codes. We urge CMS to engage stakeholders to look at this further, as well as to inform changes for the practice expense methodology, before implementing any changes.

The Academy also responded favorably to several announcements in the proposed rule. We support CMS’s proposal to streamline the process for revisions to the Medicare Telehealth Services List, as well as the removal of the provisional and permanent designations. We also thanked CMS for the addition of the auditory osseointegrated sound processor services (CPT codes 92622 and 92623) to the Medicare Telehealth Services List. CMS is looking at how to include artificial intelligence (AI) tools into the rate-setting process for the MPFS, and the Academy supports efforts to establish a clear reimbursement pathway that promotes innovation in AI-enabled technology. Finally, CMS announced in the MPFS the set of 12 new hearing device services codes, and the Academy commented on the importance of having these codes to describe more accurately the range and intensity of services provided by audiologists

A copy of the Academy’s full comment letter is available.