On September 10, the AAO-HNS submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) regarding the calendar year (CY) 2026 Medicare Physician Fee Schedule (MPFS) proposed rule. The Academy’s comments addressed the following issues most significantly impacting the specialty:
- Implementation of dual conversion factors;
- Proposed “efficiency adjustment” reducing codes’ intra-service values;
- Revisions to utilization estimates for add-on code G2211;
- Updates to practice expense calculations;
- Adjustments to the code valuation process;
- Policies related to telehealth services;
- Strategies for improving global surgery payment accuracy;
- Valuation of codes impacting otolaryngology; and
- Updates to the Quality Payment Program (QPP).
A full AAO-HNS summary regarding provisions in the proposed rule is available here.
CMS is expected to issue the final rule in November 2025. Once released, AAO-HNS staff will provide members with a summary and analysis of the rule’s final policies and CMS’s responses to our recommendations.
