CMS Moves Forward with Controversial Policy Targeting Surgical Procedures

Highlight: Gynecologic oncology surgical procedures face decrease in work RVUs in 2026.

On October 31, the Centers for Medicare & Medicaid Services (CMS) released the Medicare Physician Fee Schedule (MPFS) final rule and fact sheet for CY 2026 (CMS-1832-F). With the release of the rule CMS finalized policy that reduces work RVUs and intraservice times for 1,000’s of CPT codes including surgical procedures performed by gynecologic oncologists.

CMS was not moved by hundreds of stakeholder comments, including SGO’s, that called for the agency to abandon the efficiency adjustment policy. As such, work RVUs and corresponding intraservice times will be reduced by -2.5% for nearly every service on the fee schedule except time-based codes, including evaluation and management services, care management services, behavioral health services, services on the Medicare telehealth list, and maternity codes with a global period of MMM. CMS did make one change in response to stakeholder comments: new codes added to the fee schedule in 2026 will not be subject to the efficiency adjustment.

Per CMS, the efficiency adjustment is meant to account for efficiency gains over time as practitioners become more skilled at performing procedures taking less time to complete than the intraservice times listed in the AMA Relative Value Scale Update Committee (RUC) time files. The agency continues to believe the RUC survey process is flawed due to low response rates and perceived conflicts of interest of those who take RUC surveys and reiterated this stance in the final rule. Additionally, throughout the discussion in response to comments, CMS repeats that the agency welcomes empiric data to support the value of physician services, which is yet another indication that CMS does not want to rely solely on RUC survey data to set payment rates. CMS states “we believe that robust empiric data is important to avoid some of the shortcomings of survey data in accounting for efficiencies over time.”

The chart below illustrates an example as to how the work RVUs and intraservice time of surgical procedures are reduced through the efficiency adjustment. Although the reductions may appear small for each individual code, the cumulative impact over the course of a year will significantly affect overall reimbursement. Other services affected by this policy can be found in this list.

SGO is joining other affected specialties in urging Congress to intervene and prevent the implementation of this policy.

Take action here!