Lexology July 17, 2025
On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the proposed rule for the Calendar Year (“CY”) 2026 Medicare Physician Fee Schedule (“PFS”), formally titled CMS-1832-P. The proposed rule outlines key payment policy updates for Medicare Part B services, including changes to physician reimbursement rates, modifications to the Quality Payment Program (“QPP”), and significant structural reforms to the Medicare Shared Savings Program (“MSSP”). If finalized, these policies will take effect on January 1, 2026. CMS is accepting public comments through September 12, 2025.
While CMS has framed these updates as routine adjustments, several underlying proposals suggest a broader strategic shift toward performance-based payment and accountability, particularly within the MSSP and advanced Alternative Payment Models (“APMs”). The...
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