Medicare Physician Fee Schedules in the first half of this decade continued the long-term trend of cuts to office-based proceduralists. These year-over-year cuts have been implemented without regard to patient outcomes, actual PFS provider resource needs, or any other policy.  These cuts also reduced patient access, particularly in rural areas; accelerated the health system consolidation trend; exacerbated health inequities in a variety of diseases; and threatened the pandemic resilience of our healthcare system.

The 2026 PFS Final Rule is the first meaningful improvement for office-based providers in years. HOPD and ASC rates continue to rise, largely unaffected by the IPE policy.  An analysis of all codes common to HOPD, ASC, and non-facility settings over a 5-year period shows global facility rates have never declined year-over-year, while non-facility settings declined each year through 2025. The 2026 PFS Final Rule increases reimbursement across all three settings, despite non-facility settings remaining below 2022 reimbursement levels.  ​

Since 2021, the number of CPT codes whose total reimbursement is less than their CMS calculated direct costs has aggressively increased each year.  The Indirect Practice Expense policy in the 2026 PFS Final  Rule is an important step in the right direction, but additional actions must be taken to address this problem on a permanent basis.