The Centers for Medicare and Medicaid Services (CMS) has released the 2026 Medicare Physician Fee Schedule proposed rule and fact sheet. The rule includes new values for the revised code sets for PCI and LER as well as a new value for LAAO. The temporary increase given to the conversion factor by Congress in the One Big Beautiful Bill Act (OBBBA) provides the first positive update in years.  

Conversion Factor 

For 2026, CMS is proposing two conversion factors as there are two different update adjustments in statute. The statute provides for a .75 percent payment update for those who have been participating in a qualifying Advanced Payment Model (APM) through the Quality Payment Program (QPP). The statute also provides an update for non-APM participants at the rate of .25 percent. 

For those who participate in a qualifying APM, the conversion factor is proposed at $33.59. For those who do not qualify for the APM increase, the conversion factor is proposed at $33.42. This is an increase to the 2025 conversion factor, which is $32.36, based largely on the OBBBA temporary increase and the completion of the clinical labor phase.  

PCI Codes 

The percutaneous coronary interventions (PCI) code set underwent revisions through the CPT® and RUC processes and is now being valued by CMS. CMS accepted RUC recommendations for all 12 codes in the code set. The code set includes both increases and decreases in value. It also includes two new codes for multiple stent placement and retrograde chronic total occlusion (CTO). 

LER Codes 

The lower extremity revascularization (LER) code set also underwent CPT® revisions. CMS is also proposing to accept the RUC recommendations for the new 45 code set. CMS has also requested additional information for determining code values and is seeking comments on whether G codes or the OPPS methodology should be used for reimbursing high-cost supplies.  

LAAO Code 

Closure of left atrial appendage (LAAO) was also reviewed based on a screen from the RUC. CMS is proposing to accept RUC recommendations, which result in a 27% reduction in the work RVU from 14.00 to 10.25. SCAI will continue to work with ACC and HRS to fight this cut. 

Efficiency Adjustment 

CMS is proposing to impose an efficiency adjustment on non-timed-based codes, as a way of reducing the work RVU and intra-service time of a procedure to account for efficiencies gained over time. The proposed reduction is 2.5% on a three-year rolling schedule. The proposed adjustment would decrease the work RVUs and intra-service time by a factor equal to the MEI productivity adjustment if this factor had been applied every year over a 5-year look-back period.  

Ambulatory Specialty Model (ASM) 

CMS is proposing a mandatory value-based care model beginning January 1, 2027. The model would focus on specialists who treat heart failure and low back pain. Individuals selected to participate in the model would have been assigned a specialty code of cardiology on most of their Part B claims and have reached a threshold of claims with a heart failure diagnosis. Physicians with the specialty code of interventional cardiology will not be selected for the model, but CMS is seeking comments on which, if any, cardiology subspecialties should be included.  

G2211  

In 2024, CMS brought back the add-on code, G2211, that is used in addition to evaluation and management services for additional complexity stemming from primary care or ongoing care of complex chronic conditions. For 2026, CMS proposes expanding the use of the code to include residential and home services. 

Telehealth 

CMS is proposing to allow direct supervision using audio/video real-time communications technology for all services except those with a global surgery period of 10 or 90 days. This would include cardiac rehabilitation services. CMS states that the physician should use professional judgment on a case-by-case basis to determine the appropriate level of supervision.  

Merit-Based Incentive Program (MIPS) 

CMS has issued several requests for information (RFI) surrounding the MIPS program. SCAI is carefully reviewing them all and will provide comments as appropriate. 

CMS has proposed to maintain the performance threshold at 75 points for the 2026 performance year. CMS is also proposing that new cost measures undergo a two-year informational-only feedback period before counting as part of the MIPS score.  

CMS has proposed deleting four measures from Cardiology Specialty Measures set. The measures are 322 Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Preoperative Evaluation in Low-Risk Surgery Patients, 487 Screening for Social Drivers of Health, 498 Connection to Community Service Provider, and 508 Adult COVID-19 Vaccination Status. 

MIPS Value Pathways (MVPs) 

CMS is proposing to require a core element, or one required quality measure selected from 3-4 measures, that must be completed as part of the MVP. This element would be used as a basis of comparison between practitioners reporting the same MVP.  

CMS is also proposing to require MVP selection based on billed procedures. Specialists would be assigned to the most appropriate MVP based on a threshold of their most commonly billed codes.  

CMS has proposed changes to the Advancing Care for Heart Disease MVP including the removal of one quality measure (487 above), and three improvement activities: IA_AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols, IA_AHE_12: Practice Improvements that Engage Community Resources to Address Drivers of Health, and IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B. 

CMS is accepting public comments on the proposed rule for 60 days from the final publication date. SCAI will continue to analyze the rule and will provide comments to CMS. 

SCAI continues to fight against these payment cuts through both regulatory and legislative channels. SCAI’s Advocacy Committee and its political arm, SCAI PAC, will review the effects of these cuts and provide additional information to SCAI members for further action in the near future.