July 14, 2025

The Centers for Medicare and Medicaid Services (CMS) released the calendar year 2026 Medicare Physician Fee Schedule (MPFS) proposed rule July 14. ACR® created an initial summary  of all provisions of the proposed rule that have a direct impact on imaging practices.

Beginning Jan. 1, there will be two separate conversion factors resulting from the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The conversion factor for services provided by a qualifying alternative payment model (APM) participant is proposed to be $33.5875, inclusive of a .75% annual update. Services provided by non-APM participants have a proposed conversion factor of $33.4209, which includes a .25% annual update. Both conversion factors also include a 2.5% one-year increase to the MPFS conversion factor included in the recent budget reconciliation law, as well as a proposed 0.55% budget neutrality adjustment.

If the provisions within the proposed rule are finalized, CMS estimates an overall impact of the MPFS proposed changes to be -2% for radiology, -1% for nuclear medicine, 2% for interventional radiology and -1% for radiation oncology.

In addition to proposed payment provisions, the rule also includes proposed changes to policies for the ninth year of the Quality Payment Program and its component participation methods – the Merit-Based Incentive Payment System (MIPS) and Advanced APMs.

A detailed summary will be provided in the coming weeks.

For questions about the proposed rule, contact Angela Kim, ACR Senior Director of Economic Policy.


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