The Centers for Medicare and Medicaid Services (CMS) has released the 2026 Medicare Physician Fee Schedule (PFS) proposed rule, updating the PFS conversion factor from $32.3465 to $33.5875 for qualifying alternative payment model (APM) participants and $33.4209 for non-qualifying APM participants. This duality is required by current law. These conversion factors include the 2.5% increase passed in recent budget reconciliation legislation.

The overall reimbursement for cardiovascular services is projected to increase roughly 1% compared with 2025, including changes to policies and individual service values. Individuals and groups will see different impacts depending on patient populations and services offered.

Of note, the CMS Innovation Center is proposing a mandatory five-year Ambulatory Specialty Model (ASM) aimed at holding specialists who historically treated at least 20 Original Medicare patients with heart failure (HF) and within selected core-based statistical areas or metropolitan divisions financially accountable for management of the chronic conditions of congestive HF and low back pain. The model looks to reward specialists for effective disease management, adhering to clinical guidelines for care and coordinating with other providers involved in the management of their patients' care. The ASM is proposed for the performance period from Jan. 1, 2027, through Dec. 31, 2031, and payment period from Jan. 1, 2029, through Dec. 31, 2033.

Additional highlights from the proposed rule relevant to cardiovascular clinicians are below.

• Efficiency Adjustment: The rule proposes an efficiency adjustment to the intra-service times and work relative value units (RVUs) of nearly all non–time-based codes in the PFS. The proposal notes that there are efficiencies in performing medical services that accrue over time and are not captured in the normal process of developing the time and work RVUs. Using the Medicare Economic Index productivity adjustment for the last five years cumulatively applied, the rule proposes a 2.5% reduction to the intra-service time and work RVU of all non–time-based codes or codes that are otherwise excluded. This is the first proposal of its kind and will require the ACC's attention and collaboration with the American Medical Association (AMA) and other societies to address.
• Left Atrial Appendage Closure: Despite efforts to delay revaluation of the Left Atrial Appendage closure code 33340 due to a restricted and flawed survey or propose an alternative value, the proposed rule accepts the RUC-recommended value of 10.25, a nearly 27% reduction from the current work RVU of 14.00. The ACC will vigorously work to keep this reduction from being implemented.
• PCI: The PCI code family was revised at CPT and then resurveyed at the AMA Relative Value Scale Update Committee (RUC) in April 2024 for implementation in 2026. CMS accepted the RUC-recommended values for all 12 codes. Several codes were reduced while others saw an increase in their work RVU. New codes were created for more complex stent cases and revascularization of a chronic total occlusion to allow for more accurate valuation.
• There are no proposals to update the payment formula with information from the AMA's Physician Practice Information Survey in 2026.
• Few new Quality Payment Program (QPP) policies were proposed, signaling a continued focus on program stability. Updates to all 21 MIPS Value Pathways (MVPs), including measure inventory changes, new requirement for groups to self-identify their specialty type during registration, updates to the Total Per Capita Cost measure, and new cost measures, would have a two-year feedback-only period.
• The proposed rule includes several requests for information on MVPs, a timeline for implementing Fast Healthcare Interoperability Resources, and the Promoting Interoperability performance category.

ACC Advocacy staff will provide a more detailed breakdown of the proposed rule in the coming days including updates to QPP, telehealth and other policy changes. Look for additional information on ACC.org/Advocacy and in upcoming issues of the ACC Advocate newsletter.

More on the proposed rule can be found in the Medicare PFS Press Release, Medicare PFS Fact Sheet, Medicare PFS Addenda, Medicare Shared Savings Program Fact Sheet, and QPP Fact Sheet.