An Update on the CY2026 Medicare Physician Fee Schedule Final Rule
Prepared for Members of the Society of Gynecologic Oncology
On October 31, 2025, CMS released the CY2026 Medicare Physician Fee Schedule (MPFS) Final Rule, finalizing policies that will significantly impact gynecologic oncology practices starting January 1, 2026.
What is the Final Rule and Why does it Matter?
Each November, CMS updates the MPFS, setting reimbursement standards and policy changes for the coming year. These updates impact revenue, resource planning, and advocacy, not just technical details. Read SGO’s comment letter to the proposed rule.
As part of the final rule, CMS will publish RVUs for the next calendar year. For more detailed information see the SGO Payment Rate Chart.
Key Highlights
Efficiency Adjustment (-2.5%)
Impact: Part B providers will see a reduction for nearly all non-time-based CPT codes.
CMS Final Rule: CMS finalized the negative 2.5% efficiency adjustment to the work RVUs and intraservice time for nearly all services on the MPFS including procedures, radiology services, and diagnostic tests. The agency will exempt new codes from the efficiency adjustment for CY2026.
SGO Comments: SGO strongly opposed CMS’ proposed – 2.5% efficiency adjustment to work RVUs and intraservice time for non-time-based services, emphasizing the negative impact on gynecologic oncology practices. As a result of SGO’s advocacy, CPT codes 96547 and 96548 were excluded from the efficiency adjustment and removed from the affected code list.
Practice Expense (PE) Methodology
Impact: Facility-based physicians will face payment reductions despite ongoing indirect costs.
CMS Final Rule: CMS finalized its proposal to reduce facility-based indirect PE RVUs by half compared to non-facility RVUs.
SGO Comments: SGO opposed this change, emphasizing that facility-based physicians still incur significant indirect expenses such as salaries for administrative staff and other costs related to billing and scheduling.
Conversion Factor (CF)
Impact: Qualifying Participants (QPs) in Alternative Payment Models will see a 3.7% increase (CF = $33.5675), while non-QP clinicians will see a 3.2% increase (CF = $33.4009).
CMS Final Rule: CMS finalized two separate CY2026 CFs but reiterated that Congressional action is needed for long-term physician payment stability.
SGO Comments: SGO urged CMS to pursue permanent solutions for Medicare physician payment updates, noting that CMS cannot adjust CFs without Congressional intervention.
Strategies for Improving Global Surgery Payment Accuracy
Impact: None currently.
CMS Final Rule: CMS maintained the status quo and will continue collecting data on the global surgical package concept.
SGO Comments: SGO opposed revisions to the surgical global package and recommended that CMS rely on established processes for valuing services under the MPFS, including identifying potentially misvalued services and engaging the RUC and specialty societies in revaluation.
Payment Advocacy
For CY2026, CMS finalized changes that reduce surgical reimbursement, modify PE calculations, and present ongoing challenges for long term payment stability. To learn more about the impact on surgical care, read CMS Moves Forward with Controversial Policy Targeting Surgical Procedures and SGO’s Action Alert: Stop the Cut to Medicare Work RVUs.
SGO will continue to address both PE methodology and the efficiency adjustment as part of a broader advocacy effort.