Internal Medicine Physicians Cautiously Optimistic about Proposals in the Medicare Fee Schedule

Statement attributable to:
Jason M. Goldman, MD, MACP
President, American College of Physicians

The proposed 2026 Medicare Physician Fee Schedule rule from the Centers for Medicare and Medicaid Services (CMS) was released Tues. afternoon. While many of the provisions in the proposed rule could help to strengthen primary care and drive equity and innovation, the American College of Physicians (ACP) calls for additional congressional action to protect Medicare beneficiaries' access to their physicians by strengthening payment for primary care services and preserving access to telehealth.

On a positive note, ACP is encouraged by CMS' proposals to improve the valuation process for physician services via a new efficiency adjustment. We support CMS' acknowledgement that the time and intensity assumptions built into valuation are often inaccurate. As physicians become more efficient and technology is adopted to free them from non-clinical duties, we urge CMS to acknowledge these improvements through incentives and value-based monetary adjustments. This proposal aligns well with ACP's recommendations to adopt a more comprehensive valuation approach that combines empirical data with physician input. We will additionally be monitoring CMS' next steps to enhance the accuracy of the valuation of the global surgical packages.

ACP also supports CMS' proposals to explore how AI and other technologies can improve efficiencies and transform physician practices. However, we strongly urge CMS to ensure these technologies are intentionally integrated to serve and support physicians, reduce administrative burdens, and strengthen the patient-physician relationship.

For CY 2026, due to statutory requirements, CMS is proposing two conversion factors to support physician participation in alternative payment models (APMs), one for qualifying APM participants and another for those who are not qualifying participants. The update to the CF for 2026 is +0.75% for qualifying APMs and +0.25% for non-qualifying APMs. The proposed CF for APMs represents a projected increase of 3.83% from the current CF. For non-qualifying APMs, the projected increase is 3.62%. These changes include a one-year increase of 2.50%, also required by statute.

Several other provisions in the proposed fee schedule of interest to ACP and internal medicine:

• Although CMS is not proposing to include the Physician Practice Information Survey, which measures specialty-specific practice costs, we are encouraged by their alternative proposals to update data with greater accuracy regularly. This will help establish relative rates and inform cost assumptions. ACP has consistently recommended that these updates occur continuously, rather than waiting several years to capture rising costs retrospectively.
• The proposed rule also includes several additional provisions that may help to better support the primary care workforce, including:
  • A proposal to create optional add-on codes for Advanced Primary Care Management (APCM) services that would facilitate Behavioral Health Initiatives or Collaborate Care Model services.
  • Revisions to the APCM services to potentially include coverage of preventive services. ACP supports proposals to eliminate cost-sharing for patients to ensure access to these important services. ACP has recommended that CMS collaborate with the USPSTF to achieve this goal.
  • Streamlining how services are added to the Medicare list by removing the distinction between provisional and permanent. ACP has advocated for policies that make it easier to access audio and video services.

However, while the proposed rule has many promising provisions, we strongly oppose CMS' proposal to remove coverage of the screening for Social Determinants of Health. These screenings are crucial for ensuring that a patient's overall health is accurately represented in their care. CMS should incentivize care arrangements and services that fully capture all aspects of a patient's health and enhance the coordination of social services by improving data interoperability and reducing the burden of data collection.

###

About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 172 countries worldwide. ACP membership includes 161,000 internal medicine physicians, related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on X, Facebook, Instagram,Threads, and LinkedIn.

Contact: Laura Baldwin, (215) 351-2668, lbaldwin@acponline.org