CMS Finalizes Calendar Year 2026 Medicare Physician Fee Schedule

In this episode, Brach Eichler’s Healthcare Law team breaks down the key updates in CMS’s Calendar Year 2026 Medicare Physician Fee Schedule Final Rule. We review changes to payment rates, adjustments for QP and non-QP providers, new telehealth flexibilities, supervision standards, and important updates affecting Part B drug reimbursement and inflation-rebate calculations.

Tune in for a clear, practical overview of what providers need to know before the rule takes effect on January 1, 2026.

📲 Read the full article now: https://www.bracheichler.com/insights/cms-finalizes-calendar-year-2026-medicare-physician-fee-schedule/

For more information, contact: Caroline Patterson – 973.364.5233 – [e-mail] Jonathan J. Walzman – 973.403.3120 – [e-mail] Andrew M. Kuder – 973.403.3141 – [e-mail]

*This is intended to provide general information, not legal advice. Please contact the authors if you need specific legal advice.

Episode Transcript

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Thank you for tuning in to the Brach Eichler Talks podcast

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, where we explore and discuss today's trending legal topics.
In this episode, we'll discuss a recent article from Brach Eichler's December Healthcare Law
Update titled, "CMS finalizes calendar year twenty twenty six Medicare physician fee schedule."
On October 31, 2025, the Centers for Medicare and Medicaid Services (CMS) published the

(00:27):
calendar year (CY) 2026 Physician Fee Schedule Final
Rule, which takes effect January 1st, 2026.
The rule updates Medicare Part B payment policies under the Physician Fee Schedule, introduces
changes to quality and payment model programs, and reflects a broader focus on efficiency,
transparency, and shifting modalities of care.

For CY 2026, CMS will use two separate conversion factors (00:48):
one for practitioners who are
Qualifying Participants (QPs) in Advanced Alternative Payment Models (APMs) and another for non-QPs.
The final conversion factor for QPs is approximately $33.57, representing a 3.77%
increase over the CY 2025 conversion factor; and the non-QP CF is approximately $33.40,

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representing a 3.26% increase.
The final rule also includes an efficiency adjustment of -2.5% for non-time-based services,
reflecting CMS's view that certain services have become more efficient over time and thus their
relative value requires adjustment… For providers who offer telehealth services,

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CMS has streamlined the process for adding services to the Medicare Telehealth Services List,
eliminating the prior "provisional" versus "permanent" distinction and reducing review steps for
whether a service furnished via interactive, two-way audio-video qualifies.
In addition, the frequency limitations that previously applied to subsequent inpatient visits,

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nursing facility visits and critical care consultations delivered by telehealth have been
removed… CMS has also finalized rules allowing for direct supervision via real-time
audio-video (but not audio only) for most services that previously
required the supervising physician to be physically present.
Further, FQHCs and rural health clinics will be

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permitted to bill for telehealth services through 2026.
The Final Rule also updates several policies affecting drugs and
biological products covered under Medicare Part B.
CMS maintained the existing refund requirements for discarded amounts of certain single-dose or
single-use drugs, and adopted clarifications to how manufacturers should report pricing and

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service-fee information when calculating average sales price.
CMS also confirmed that beginning in 2026, prices for drugs subject to a "Maximum Fair Price"
will be reflected in Medicare's payment calculations.
In addition, CMS finalized operational updates to the Medicare Prescription Drug Inflation
Rebate Program aimed at strengthening price-inflation guardrails and

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improving data accuracy for future rebate determinations.
For more information, contact Caroline J. Patterson, Member and Vice Chair, Healthcare Law
at 973-364-5233 or [e-mail], or Jonathan J.
Walzman, Member, Healthcare Law at 973-403-3120 or [e-mail], or Andrew M.

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Kuder, Associate, Healthcare Law at 973-403-3141 or [e-mail].
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For more information and resources, visit Brach eichler dot com.

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This is intended to provide general information, not legal advice.
Please contact the authors if you need specific legal advice.
Brach Eichler LLC is a full service law firm based in Roseland, New Jersey with over eighty attorneys.
The firm is focused on the following practice areas, healthcare law, real estate, litigation
, trusts and estates, business transactions and financial services, personal injury, criminal

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defense and government investigations, labor and employment, environmental and land use,
family law services, patent, intellectual property, and
information technology, real estate tax appeals, tax, and cannabis.