Analysis: 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule

With many policy proposals introduced in the more than 1,800-page 2026 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule, MGMA Government Affairs created a member-exclusive key takeaway analysis highlighting the top policy proposals impacting group practices. The 2026 PFS and QPP proposed rule was released on July 14, 2025, and includes policy proposals that would:

• Create two conversion factors based on qualified participant (QP) status, both with increases from last year;
• Make changes to work and practice expense RVUs;
• Make changes to Medicare telehealth;
• Make changes to the Merit-based Incentive Payment System (MIPS), including maintaining the current performance threshold;
• Make numerous changes to the Medicare Shared Savings Program (MSSP).

These policies are only proposals and could be changed in the final PFS and QPP rule, which is typically released around Nov. 1 of each year. MGMA will submit formal comments in response to the proposed rule and will provide an updated analysis summarizing the final payment policies impacting practices in 2026.

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