ACR Pushes Back on CMS Payment Changes in MPFS Proposed Rule

ACR^® submitted comments to CMS about the 2026 Medicare Physician Fee Schedule (MPFS) proposed rule, strongly opposing a 2.5% “efficiency” cut to non-time-based procedures.

Advancements in imaging technology have not reduced radiologists’ workload. Higher-resolution imaging and AI tools generate substantially more images and require greater interpretive skill, cognitive effort, and documentation. Applying across-the-board payment cuts in this context undervalues radiologists’ expertise, may limit patient access to timely imaging, and may discourage adoption of new technologies.

ACR urges CMS to collaborate with physicians and specialty societies to ensure fair, stable payments. The College voiced general support for creation of radiology-specific MIPS Value Pathways but raised concerns about limited measures and small practice impacts. ACR also provided input on a number of other CMS proposals – including: 

• Practice Expense Methodology and Cost Share Weights
• Site of Service Differentials
• Direct Supervision via Use of Two-way Audio/Video Communications Technology
• Valuation of Specific Codes for 2026
• CY 2026 Identification and Review of Potentially Misvalued Services
• Payment Policy for Software as a Service
• MR Safety Codes on the Multiple Procedure Payment Reduction List
• MIPS Scoring Overview

The College continues to work with CMS on radiology and radiation oncology issues and will keep members informed as the rulemaking process advances toward publication of the MPFS final rule in late fall.

For more information, contact Angela Kim, ACR Senior Director of Economics Policy.