CY 2026 Medicare Physician Fee Schedule final rule: Advocacy yields gains and new challenges

The Centers for Medicare & Medicaid Services (CMS) released the CY 2026 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program final rule, and the AOA has prepared a high-level summary of the changes most relevant to osteopathic physicians and their practices. AOA advocacy delivered several important wins, including a positive conversion factor update and long-sought stability in MIPS participation thresholds, while also noting areas of concern where finalized policies will negatively impact payment for many specialties.

Positive conversion factor update

AOA helped secure a +2.5% increase to the 2026 conversion factor and preserved the MACRA +0.75%/+0.25% updates beginning in 2026.
CMS will implement separate conversion factors for qualifying APM participants and non-APM physicians, with both seeing increases over 2025.

Stability in MIPS

CMS is maintaining the MIPS performance threshold at 75 points for performance year 2026 through 2028, an AOA priority to protect small and independent practices still recovering from COVID-19, prior exemptions and the Change Healthcare cyberattack.

At the same time, the AOA is disappointed that CMS finalized:

A -2.5% “efficiency adjustment” to work RVUs for non–time-based services, with osteopathic manipulative treatment (OMT) codes not exempted.
A new practice expense methodology that reduces the share of indirect PE RVUs tied to work RVUs for facility-based services.

The rule also finalizes policies on telehealth, the upcoming Ambulatory Specialty Model and improved payment for chronic care and behavioral health services. The AOA will continue to advocate for long-term, Medicare physician payment reform to support the members we serve.