Healthcare Advocacy Toolkit 2025 - Vol. 2

Medicare Reimbursement: What’s Changing CMS Proposed New “Efficiency Adjustment” in 2026 Medicare PFS The 2026 Medicare PFS includes a notable policy shift: a new “ efficiency

adjustment ” that reduces work values for certain services to reflect perceived gains from technology and provider experience. This signals a shift in CMS’s valuation methodology for physician services. Key Points: • -2.5% adjustment to work RVUs and intraservice time for non-time- based services • Designed to reflect productivity gains from technology and experience • Excludes time-based services like: Evaluation & Management (E/M) visits, care management, etc.

CMS Proposed Dual Conversion Factors & Site Neutrality Implications The 2026 Medicare PFS

Proposed Rule includes major structural changes, including two separate conversion factors (CFs) and a strong push toward site-neutral payments. Key Points: • Two CFs: +3.83% (APM)

and +3.32% (non-APM), temporarily boosted for 2026 by OBBBA

• New focus on site-

neutrality : facility-based specialties may see cuts • Permanent virtual direct supervision allowed • Move away from survey-based valuation methods

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