On July 16, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year (CY) 2026 Proposed Rule for the Medicare Physician Fee Schedule (MPFS), which also includes proposals related to the Quality Payment Program (QPP). CMS is soliciting public comment on the rule through September 12, 2025. The Academy will submit a comprehensive response to the proposals contained in the rule by this date. While AAO-HNS physician leaders and staff are still reviewing this extensive document, the following is a high-level summary of key proposals impacting the specialty.
Conversion Factor and Overall Payments
- CMS has proposed two separate conversion factors for CY2026. Physicians participating in a qualifying alternative payment model (APM) will receive an increase of 0.75%, and physicians not participating in a qualifying APM will receive an increase of 0.25%. Also included is a one-year statutory increase of +2.50% and an estimated +0.55% adjustment to account for proposed work Relative Value Units (RVU) changes. The total respective proposed conversion factors are below:
The proposed CY2026 qualifying APM conversion factor is $33.59, an increase of $1.24 or +3.83% from the 2025 conversion factor.
For those not qualifying under an APM, the conversion factor $33.42, an increase of $1.17 or +3.62% from the 2025 conversion factor.
Estimated Impact to Otolaryngology
- CMS estimates the overall impact of the MPFS proposed changes to be 0% for otolaryngology. It is important to note that this does not include the proposed +3.83% or +3.62% increase that all clinicians are subject to based on their APM status.
Efficiency Update
- For the first time, CMS is proposing a new “efficiency adjustment” that would reduce the intra-service values for most non-time-based CPT codes beginning in 2026. This negative adjustment reflects the CMS assertion that time assumptions built into the valuation of many procedures and services are overinflated due to increases in physician efficiency and technological advances over time. To quantify this perceived efficiency, CMS is proposing a reduction of -2.5% to intra-service time inputs, which would, in turn, reduce associated work RVUs. This adjustment would impact nearly all otolaryngology codes except certain telehealth services and inherently time-based codes, such as some E&M services. This -2.5% figure is derived from the average productivity adjustment applied to the Medicare Economic Index (MEI) over the past five years.
Payment for Telehealth Services
Status of Audiology and Speech Language Pathology CPT Codes
- To streamline the process for adding services to the Medicare Telehealth Services List, CMS is proposing to permanently remove the distinction between “permanent” and “provisional” services. Instead, the inclusion of such services will be determined based on whether the service can be furnished using an interactive, two-way audio-video telecommunications system. Several Audiology and Speech-Language Pathology codes that were previously assigned a “provisional” status on the CY2025 Medicare Telehealth Services list will now be included on a permanent basis for CY2026.
New Guidance for Physician Supervision
- For CY2026, policies requiring in-person supervision of residents in all teaching settings will once again take effect. These policies were temporarily lifted during the COVID-19 Public Health Emergency. Beginning in January 2026, to qualify for Medicare payment, CMS will require teaching physicians to maintain a physical presence when supervising residents in all teaching settings, with exceptions for certain rural practice settings.
- For services that are required to be performed under direct supervision, CMS is permanently adopting a definition of direct supervision that will allow the physician or supervising practitioner to supervise through real-time audio and visual interactive telecommunications (excluding audio-only).
Merit-Based Incentive Payment System (MIPS)
For the Merit-Based Incentive Payment System (MIPS) categories and scoring, CMS has proposed the following for CY2025:
For the Quality Performance category:
- Data completeness is maintained at 75% for most measures.
- Flat benchmarking is proposed for topped out measures within designated specialty measure sets to prevent inflated scoring and ensure fairness.
- Updates to the APP Plus measure set are proposed to maintain alignment with the broader MIPS quality inventory.
For the Cost Performance category:
- The Total Per Capita Cost (TPCC) measure will include updated candidate event and attribution rules to improve accuracy.
- New cost measures will have a two-year informational feedback period during which clinicians receive performance feedback, but the scores will not affect the final MIPS score.
For the Improvement Activities category:
- Three new activities are proposed, and seven activities are proposed for modification.
- Eight activities are proposed for removal.
- A new subcategory titled, “Advancing Health and Wellness” is proposed, while the current “Achieving Health Equity” subcategory would be removed.
For the Promoting Interoperability category:
- Updates are proposed for the SAFER Guide and Security Risk Analysis measures.
- A new optional or bonus measure is proposed for Public Health Reporting using the Trusted Exchange Framework and Common Agreement (TEFCA).
- A new suppression policy is proposed, allowing certain measures to be temporarily removed from scoring if necessary.
- The Electronic Case Reporting measure is proposed to be suppressed for the CY2025 performance period due to the CDC’s temporary pause in onboarding new healthcare organizations.
Final score:
- The performance threshold is proposed to remain at 75 points through the CY2028 performance period, corresponding to the 2030 MIPS payment year, in order to provide consistency and predictability in scoring.
MIPS Value Pathways (MVPs)
- Groups will attest to being either single-specialty or multispecialty small practices at the time of MVP registration. CMS will not determine this on their behalf.
- Multispecialty small practices may continue reporting as a group, and subgroup reporting will remain optional through the CY2026 performance period.
- Qualified Clinical Data Registries (QCDRs) and Qualified Registries will be given one year after MVP finalization to fully support implementation and integrate necessary system changes.
- CMS has proposed the reinstatement of AAO16: “Age-Related Hearing Loss: Audiometric Evaluation” as a measure within the Quality Care for the Treatment of Ear, Nose, and Throat Disorders MVP.
- Additionally, CMS has proposed the removal of quality measure, “Screening for Social Drivers of Health” from the ENT MVP.
Practice Expense RVUs and Any Other Coding Changes
For CY2026, CMS proposes to continue implementing the supply pack pricing update and associated revisions as previously recommended by the RUC’s workgroup. See below for those that are included commonly in ENT PE inputs.
Strategies to Update Practice Expense (PE) Data Collection
- CMS acknowledges the continued decline in private practice among physicians and the corresponding growth in hospital and health system employment. Given this shift, CMS believes that the current method of allocating identical indirect practice expense (PE) costs across both facility and non-facility settings may no longer align with how care is delivered today. To better reflect the lower indirect costs typically incurred by physicians practicing in facility settings, CMS proposes that beginning in CY2026, the portion of facility PE RVUs allocated based on work RVUs be reduced to half the amount used in non-facility (office-based) settings.
- CMS also proposes a longer-term strategy to improve the accuracy and transparency of PE valuation. Specifically, CMS is considering moving away from reliance on AMA-conducted survey data for some PFS services and instead using more routinely updated, auditable data sources—such as hospital data from the Medicare Outpatient Prospective Payment System (OPPS)—particularly when valuing technical services. According to CMS, this shift could enhance rate-setting predictability, promote transparency, and reduce reliance on less consistent or anecdotal survey inputs. However, CMS is not proposing to implement this change in 2026.
- CMS is soliciting comments on whether the proposed reduction in facility PE RVUs accurately reflects the indirect costs for physicians in facility settings and asks for suggestions regarding additional data sources that could help refine these estimates in the future. These comments are expected to be addressed in future rulemaking.
Potentially Misvalued Services Under the PFS
Maxillofacial Prosthetic Services (CPT codes 21076, 21077, 21079, 21080, 21081, 21082, 21083, 21084, 21085, 21086, 21087)
- An interested party nominated these codes as potentially misvalued. The nomination stated that the practice expense and work inputs may have changed with technological advancements over time. CMS is not proposing to nominate these codes as potentially misvalued; they welcome public comments and recommendations to better understand the inputs for these codes.
Supervision of preparation and provision of antigens for allergen immunotherapy (CPT codes 95145, 95146, 95147, 95148, 95149)
- The nominator cited higher labor and raw materials cost to manufacture venom therapy since the last RUC review. CMS is not proposing to nominate these codes as misvalued. CPT codes 95115 and 95117 are typically billed in conjunction with these codes; CMS asserts that there are overlapping inputs for these codes. CMS seeks feedback on the overlapping components of these codes and efforts to reduce duplicative payments.
Electronic analysis of implanted neurostimulator pulse generator/transmitter (CPT codes 95970, 95976, 95977)
- The nominator illuminated a significant change in the clinical specialties that utilize these codes, moving from primarily neurology and shifting toward sleep specialists. Given this, they maintain there should be changes to the work RVUs and PE inputs. Though CMS is not proposing to consider these codes as potentially misvalued, they are seeking comments and additional information on the information provided by the nominator.
Fine Needle Aspiration (FNA) (CPT codes 10021, 10004, 10005, 10006)
- The nominator for these codes disagrees with the past work RVU reductions for FNA procedures, arguing the crosswalk comparison used is inappropriate. They cite a shift in these procedures from office-based settings toward hospital facilities. CMS has proposed to maintain their position and are not proposing this code family as potentially misvalued.
Nasal sinus irrigation (CPT codes 31000 and 31002)
- An interested party nominated CPT codes 31000 [Lavage by cannulation; maxillary sinus (antrum puncture or natural ostium)], and 31002 (Lavage by cannulation; sphenoid sinus) as potentially misvalued. The nominator identified two issues 1) the procedure uses the Cyclone® sinonasal suction and irrigation system and requires additional tools, staff time, and supplies that are missing from the current valuation and 2) neither code has non-facility RVUs but are primarily performed in the non-facility setting. Although CMS does not currently propose to designate these codes as potentially misvalued, they acknowledge the interested party’s concerns about their current valuation. CMS welcomes public comments regarding these issues concerning CPT codes 31000 and 31002. Interested parties are encouraged to submit relevant documentation, such as invoices or other evidence, that demonstrates the typical resource costs for providing these services.
Valuation of Services
Tympanostomy (CPT code 0583T)
- CMS received requests that a national price for CPT code 0583T be created in addition to the efforts made in the CY2025 rule creating the add-on code G0561. CMS is seeking comments on whether or not a national price for both codes is necessary and what inputs for physician work, time, and direct practice expense would most accurately capture the resource costs associated with performing both procedures.
Hearing Device Services (CPT codes 9X01X, 9X02X, 9X03X, 9X04X, 9X07X, 9X08X, 9X09X, 9X10X, 9X11X, 9X12X, 9X13X, and 9X14X)
- At the February 2024 CPT Editorial Panel meeting, 12 new Category I codes were created to report hearing devices services (for example, air-conduction hearing aids), including hearing aid candidacy determination, hearing aid selection, hearing aid fitting, follow-up after fitting, hearing aid verification, and assistive-device services. The current CPT codes, 92590- 92595, were recommended for deletion. The RUC is recommending contractor pricing for all 12 codes in the family. However, section 1862(a)(7) of the Act prohibits Medicare payment under Part A or Part B for any expenses incurred for hearing aids or examinations, therefore, it has been established CMS policy not to pay for these hearing device services on the PFS, as their predecessor CPT codes 92590-92595 all have non-payable status codes. Therefore, they are proposing to maintain the same policy of assigning non-payable status codes to each of the 12 new CPT codes in this family.
