ACP Says 2026 Medicare Physician Fee Schedule Changes Will Better Support Primary and Comprehensive Care
Statement attributable to:
Jason M. Goldman, MD, MACP
President, American College of Physicians
WASHINGTON, November 5, 2025—The final 2026 Medicare Physician Fee Schedule makes several changes that will help to better support the primary and comprehensive health care provided by internal medicine specialists. The American College of Physicians (ACP) was encouraged to see that the Centers for Medicare and Medicaid Services (CMS) finalized many of the proposed changes in the rule they released earlier this year.
ACP is glad to see that the fee schedule finalized the introduction of an efficiency adjustment that will help account for how clinical practices and resource utilization patterns evolve and better align payments with those changes. ACP appreciates CMS’s decision to exclude evaluation and management (E/M) services from the efficiency adjustment. The work associated with E/M services has become increasingly complex and intensive due to the need for comprehensive, person-centered and relationship-based care, which is essential to primary care. ACP is concerned, though, that CMS finalized its plan to reapply the adjustment every three years. We believe that CMS should provide the health care community with opportunities to address and provide input on future adjustments in a data-driven manner.
CMS also finalized updates to its practice expense determination methodology to better recognize indirect costs for physicians in office-based settings. This change will help support physicians in independent practices, including the next generation of physicians who wish to establish their own practices. However, ACP remains concerned that some subspecialties may face a disproportionate impact from the changes. CMS should mitigate these impacts by phasing in this change over several years.
Additionally, ACP is glad to see that behavioral health services have been added to the list of assignable primary care services under the Advanced Primary Care Management (APCM) model. Behavioral health is a critical component of comprehensive primary care. ACP also urges CMS to move forward with removing cost-sharing for APCM services, as any amount could be prohibitive, resulting in limiting the uptake of APCM services.
Many of the provisions in next year’s fee schedule are promising for physicians, however we are still faced with the issues caused by the requirement that physician payments remain budget neutral and not increase their overall cost. Because of this requirement, while some physicians will see increases, others will be subject to payment cuts for arbitrary reasons unrelated to the work they perform for patients. Budget neutrality has repeatedly caused major issues with reimbursements, and it prevents physician payments from being able to adequately reflect the value of the increasing cost of providing care.
Finally, ACP is concerned that, although the final rule contains a few telehealth-related proposals, the ongoing government shutdown has led to a lapse in telehealth flexibilities, preventing most Medicare beneficiaries from accessing telehealth services. Congress must pass legislation to permanently enable Medicare patients to receive care via telehealth; short-term extensions and lapses in funding result in inconsistent access and confusion for both patients and physicians.
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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 162,000 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, and subscribe to our new RSS feed.
Contact: Jacquelyn Blaser, JBlaser@acponline.org, 202-261-4572