CMS Proposes a Small Increase in Anesthesia Payments in 2026; Maintains Anesthesiology Quality Payment Program Features

On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule, which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). Within the fee schedule, CMS proposed Medicare payment updates to the Anesthesia Conversion Factor that will not improve the financial strain that anesthesia groups are facing. The proposed rule has a 60-day comment period. Final regulations will be issued on or around November 1 and unless otherwise noted, policies will be effective on January 1, 2026.

ASA is disappointed with these woefully low payment updates included in the CY 2026 PFS proposed rule. These updates will not provide much relief for the physician practices that are struggling to cover their costs. The proposed rule underscores how the Medicare payment system is broken, especially during a time when anesthesia groups are faced with continued inflation pressures. ASA will continue to engage legislative stakeholders and regulatory agencies to erase this negative impact on anesthesiologists.

Fee Schedule Provisions:

CY 2026 marks the first year that the PFS conversion factor (CF) will differ based on whether qualified clinicians are participating in an Advanced Alternative Payment Model (APM). MACRA provides for a 0.75% base payment update for items and services furnished by Qualifying APM Participants and a 0.25% base payment update for other items and services. As a result, the proposed 2026 anesthesia CF is:

• $20.6754 for items and services furnished by Qualifying APM Participants, representing a 1.8% increase from the 2025 anesthesia CF of $20.3178.
• $20.5728 for other items and services, representing a 1.26% increase from the 2025 anesthesia CF.

The proposed 2026 RBRVS CF is:

• $33.5875 for items and services furnished by Qualifying APM Participants, which reflects a 3.84% increase relative to the 2025 CF.
• $33.4209 for other items and services, which reflects a 3.32% increase relative to the 2025 CF.

The change to the PFS CF incorporates several factors:

• A statutory annual update of +0.75% for items and services furnished by Qualifying APM Participants and an update of +0.25% for other items and services, as authorized under MACRA.
• A +0.55% budget neutrality adjustment, required by law, to offset changes in work Relative Value Units (RVUs) for some services. This means spending in one year needs to be balanced by reductions and CMS cannot increase or decrease expenditures by more than $20 million without triggering automatic budget neutrality adjustments.
• A temporary +2.5% increase in physician payments for 2026, authorized in the recent budget reconciliation package, One Big Beautiful Bill Act (H.R. 1). As a reminder, physician payments were reduced by 2.83% in 2025 after a temporary increase in payments for 2024 expired.

CMS is also proposing to apply an efficiency adjustment of -2.5% to the work RVUs and corresponding intraservice portion of physician time of non-time-based services for services that CMS expects to accrue gains in efficiency over time.

Specialty Impact on Anesthesia and Pain Medicine

Actual payment rates are impacted by a range of proposed policy changes related to physician work, practice expense, and malpractice RVUs. CMS estimated these changes in Table 92 in the proposed rule. Impact by practice will vary based on service mix. Specialty impacts ranged from -6% for Infectious Disease to +7% for Allergy/Immunology. The table indicates that the impact of policies in the proposed rule will have on anesthesiology and interventional pain management.

Note, changes to the CF are not reflected in the impact table. The figures below are CMS estimates.

*Note: The 0.75 percent and 0.25 percent updates to the CY 2026 qualifying APM and nonqualifying APM conversion factors, respectively, as well as the single year increase of 2.50 percent to the conversion factor for CY 2026, are statutory changes that take place outside of BN, and therefore, are not captured in the specialty impacts displayed in Table 92.

Source: Table 92, CY 2026 PFS proposed rule, display copy

Pain Medicine Code Updates

We are happy that CMS accepted the RUC recommendation for the newly created Percutaneous Image-Guided Lumbar Decompression (PILD) for Lumbar Spinal Stenosis codes.

ASA requested new CPT codes in early 2024. ASA surveyed its members in the fall 2024 to develop value recommendations to these codes. The recommendations were presented at the January RUC meeting.

Starting January 1, 2026, pain medicine physicians will be able to get paid by Medicare for Lumbar Decompression services using the new category I PILD CPT codes (62XX0 and 62XX1). For CY 2026, CMS has proposed the following work RVUs for the PILD codes, which are the same as the RUC recommended value. The table below reflects CMS's proposed work RVUs for the fascial plane block codes.

Other Major Provisions

CMS proposes to streamline its process for adding services to the Medicare Telehealth Services List to eliminate the distinction between provisional and permanent services and to limit its review on whether services can be furnished using interactive, two-way audio-video telecommunications system. CMS also proposes to remove frequency limits for certain services, including subsequent inpatient visits.

CMS also revisited its concerns regarding the valuation of global surgery packages and, in particular, the number of post-operative visits included in the packages versus the number of post-operative visits actually delivered. In order to improve the value of global surgery packages, CMS seeks comment the portion of the package that is attributable to the procedure, practice standards as it relates to surgeons and providers who deliver post-operative care to their patients, and post-op visit data collection opportunities.

Please contact [email protected]with any questions related to the Medicare Physician Fee Schedule.

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Quality Payment Program Provisions:

CMS also released its 2026 Quality Payment Program (QPP) proposals. The proposed rule provides details on how CMS intends for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models and other features of the QPP during the 2026 performance year.

For the 2026 reporting year:

• CMS is proposing to maintain the performance threshold at 75 points through CY 2028. Scoring below 75 points would result in a payment penalty in 2028.
• By law, the weights of the different MIPS requirements will not change: the quality performance category will be weighted at 30% and the cost performance category will be weighted by 30%. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.
• ASA opposes the proposed removal of QID424: Perioperative Temperature Management for the following reasons: the quality action being measured has become a standard of care, based upon MIPS performance data, and thus has limited opportunity to improve clinical outcomes.
• CMS will maintain the data completeness threshold for the MIPS Quality Performance Category at 75% for the 2026 through 2028 performance years.
• CMS proposes adding three anesthesiology quality measures to those eligible for alternative benchmarking (QID430, QID463, QID477)

Anesthesiologists will continue to have the opportunity to report the Anesthesiology MIPS Value Pathway in 2026. MIPS Value Pathways (MVP), CMS believes, will alleviate some of the reporting burdens that anesthesiologists and other physicians encounter in the MIPS program. For 2026, CMS has proposed the removal of two quality measures from the MVP:

• QID424: Perioperative Temperature Management
• QID487: Screening for Social Drivers of Health

CMS is proposing the removal of two Improvement Activities from the MVP:

• IA_CC_2: Implementation of improvements that contribute to more timely communication of test results
• IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B.

CMS is also proposing to launch the Ambulatory Specialty Model (ASM), a mandatory alternative payment model that was developed based on the MVP framework. The model, which would run from 2027 to 2031, would target specialists who frequently treat low back pain or heart failure in selected geographic areas. Eligible physicians, including anesthesiologists and pain management providers, will be assessed individually and subject to performance-based payment adjustments ranging from -9% to +9% in the first year.

CMS also issued seven RFIs in this proposed rule that ASA expects to review and comment on. Those RFIs are Core Elements in an MVP, Well-being and Nutrition Measures, Procedural Codes for MVP Assignment, Digital Quality Measurement and FHIR® Standards, Query of Prescription Drug Monitoring Program (PDMP) Measure, Public Health and Clinical Data Exchange Objective, and Data Quality.

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].

ASA leaders and staff will review the rule and submit comments by the deadline. Unless otherwise noted, finalized provisions will become effective on January 1, 2026.

For more information:

• Proposed Rule text
• CMS Press Release
• CMS Fact Sheet on the Medicare Shared Savings Program (MSSP)
• CMS Fact Sheet on the Quality Payment Program