August 5, 2025
Policy Update: CMS Proposes Updates to Medicare Physician Fee Schedule Payments for Calendar Year 2026, Comment by September 12
This proposed rule from the Centers for Medicare & Medicaid Services (CMS), issued on July 16, 2025, seeks public comment on payment updates and policy changes to Medicare’s physician fee schedule payments and includes other proposals affecting Medicare beneficiaries.
Proposals include:
- Removing the code and add-on payment for the Social Determinants of Health Risk Assessment,
- Permanently adopting the definition of direct supervision that allows the physician or supervising practitioner to provide supervision through real-time audio and visual interactive telecommunications (excluding audio-only),
- Creating optional add-on codes for Advanced Primary Care Management (ACPM) services that would provide behavioral health integration or psychiatric Collaborative Care Model (CoCM) services proposed modifications to the way that CMS will pay for skin substitutes,
- A proposed negative 2.5 percent adjustment to certain non-time-based Relative Value Units (RVUs), and
- A new mandatory alternative payment model, the Ambulatory Specialty Model.
The proposed rule also includes proposed updates applicable to Rural Health Clinics (RHCs), including:
- Extending non-behavioral health telehealth flexibilities through December 31, 2026,
- Requiring an in-person mental health service within 6 months prior to the mental-health telehealth visit and requiring an in-person mental health visit every 12-months while the patient is receiving services,
- Requiring RHCs and FQHCs to report and bill the individual codes for BHI and CoCM rather than the current consolidated code.
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