American College of Rheumatology Submits Response to CY 2026 Medicare Physician Fee Schedule Proposed Rule
ATLANTA – The American College of Rheumatology (ACR) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed Calendar Year (CY) 2026 Medicare Physician Fee Schedule (MPFS), highlighting proposed policies, including changes to the Conversion Factor (CF), code valuations, telehealth flexibilities, and payments for Part B services and drugs. These issues will impact rheumatology care providers and the more than 53 million Americans living with rheumatic diseases.
The letter notes that although CMS has proposed an increase to the CY 2026 CF, its impact will be nominal and does not go far enough to resolve decades of Medicare reimbursement cuts for physicians. When adjusted for inflation, Medicare physician payments have declined by 33% since 2001. The ACR has argued that this boost in reimbursement is only temporary, and is not sufficient for providers, especially rheumatologists, who require specialized staff and equipment to deliver care to patients. The comments instead call for long-term payment reform with updates to the CF tied to inflation to aid the viability of physician practices and reduce consolidation.
The ACR also expresses concern that changes in code valuations could erode any gains made by the increase in the CY 2026 CF, noting that while CMS has made efforts in recent years to appropriately value and strengthen access to cognitive specialists, the -2.5% proposed efficiency adjustment could threaten beneficiary access to care and jeopardize our healthcare system’s sustainability.
The comments do applaud CMS proposed efforts to expand and improve telehealth services, noting, “These changes will directly benefit patients with complex rheumatic diseases by enabling timely follow-up, continuity of care, and practice efficiency.” However, the ACR also expresses concern about the impending expiration of the originating site and geographic restrictions for telehealth services. The letter asks CMS to work with Congress to permanently extend all regulatory flexibilities on telehealth reimbursement and remove restrictions on payment parity and interstate licensure.
Regarding Part B services, the ACR expresses concern that CMS’s proposal to include drugs sold at the Maximum Fair Price (MFP), as determined through the Medicare Drug Price Negotiation Program, will be included in Average Sales Price (ASP) calculations, thereby lowering the current ASPs for Part B drugs. This will create a ripple effect where reimbursements from Medicare, Medicaid, and even commercial insurers could be influenced downward. If ASP is reduced due to inclusion of MFP, Medicare payments to practices may no longer cover acquisition costs. This could force small or independent practices to administer drugs at a loss, leading to site-of-care shifts.
Also, the comments express apprehension regarding rebates between manufacturers of originator biologic medications and pharmacy benefit managers (PBMs). These rebates lower the ASP for certain biosimilar drugs and lead to “underwater payment” for providers paying more for medications than they are reimbursed. The ACR notes, “The increased financial pressure on rheumatologists that often accompanies rising infusion costs frequently requires them to make difficult decisions when it comes to patient care.” The comment letter instead “strongly encourages CMS to not move forward with this provision,” or if this provision does move forward, they encourage the inclusion of a reimbursement floor.
"Sooner or later, policymakers must address our outdated and unsustainable Medicare Physician payment system, but unfortunately, this proposed rule doesn’t do it. This conversion factor increase doesn't offset the decades of Medicare physician reimbursement cuts, and the proposed efficiency adjustment disregards key factors related to the time and complexity required from physicians when it comes to patient care. Ultimately, these policies will add to the financial burden many practices are already facing," said Dr. Carol Langford, president of ACR. "Expanded telehealth services have been a positive game-changer for many patients with rheumatic disease, particularly for those who are immunocompromised or have limited mobility, such that we call on policymakers to create permanency around telehealth flexibilities to ensure patients can continue to benefit. The time to protect practice sustainability and patient access to high-quality care is now."
See the ACR's full comment letter >
Media Contact
Teri Arnold
tarnold@rheumatology.org
757-272-7002 (cell)
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About the American College of Rheumatology
The American College of Rheumatology (ACR) is an international medical society representing over 10,500 rheumatologists and rheumatology professionals with a mission to empower rheumatology professionals to excel in their specialty. In doing so, the ACR offers education, research, advocacy and practice management support to help its members continue their innovative work and provide quality patient care. Rheumatologists are experts in the diagnosis, management and treatment of more than 100 different types of arthritis and rheumatic diseases.