4 takeaways from the AAFP’s response to the 2026 MPFS proposed rule
Oct. 16, 2025, News Staff—Planned increases to Medicare family physician payment next year represent welcome progress within a system threatened by health care consolidation, the AAFP told CMS in response to the 2026 Medicare physician fee schedule (MPFS) proposed rule.
Here are four key takeaways for members.
1. Medicare payment boost comes from two conversion factors and efficiency adjustment
A decade after the Medicare Access and CHIP Reauthorization Act (MACRA) set out to improve Medicare physician payment, one of that law’s requirements will be enacted for the first time next year: a separate conversion factor (CF) for qualifying alternative payment model (APM) participants. The change is meant to further enhance incentives for practices to evolve beyond fee-for-service medicine.
The 2026 APM conversion factor of $33.59 would be $1.24 (3.83%) more than the 2025 rate ($32.35). The proposed 2026 non-APM conversion factor of $33.42 marks an increase of $1.07 (3.3%) from the 2025 rate ($32.35). These may fluctuate slightly in the final rule. (A CMS press release incorrectly stated that the non-APM CF would increase by $1.17, or 3.6%.)
As the Academy’s initial summary of the proposed rule indicated, the increase to both conversion factors breaks down as follows:
- For both CFs, 2.5% of the increase is attributable to H.R. 1
- A statutorily required update of .75% for the APM CF and .25% to the non-APM CF
- An additional .55% increase necessary to account for proposed changes in relative value units (RVU) for some services (meaning a positive budget-neutrality adjustment)
Because the increases from H.R. 1 will expire at the end of 2026, the Academy will continue its longtime press to secure permanent Medicare payment reform, including an annual inflationary adjustment.
Urge Congress to fix Medicare physician payment
Because the increases from H.R. 1 will expire at the end of 2026, the Academy will continue its longtime press to secure permanent Medicare payment reform, including an annual inflationary adjustment.
The RVU-related increase, meanwhile, would come from applying a new efficiency adjustment to non-time-based codes, excluding evaluation and management (E/M) visits. CMS notes in its proposal that many existing codes are incorrectly valuated because of inaccurate times; the Academy agreed with this assessment and expressed support for the proposal’s exclusion from the adjustment of time-based codes such as E/M, care management and maternity care.
This adjustment should improve the valuation of services for most family physicians because the conversion factor would increase as procedural codes are adjusted downward, with E/M RVU values holding steady.
2. CMS should improve its data sources and collection practices
CMS suggests in the proposed rule that it could consider alternatives to AMA survey data when valuing codes, citing low response rates to such surveys. The goal would be to more accurately value services and help address what the MPFS characterizes as “distortions” to service valuations.
“The AAFP agrees that CMS should continue to seek and use empiric, accurate time data sources,” the letter said.
The Academy added that it welcomed CMS’ proposal to recognize greater indirect costs for practitioners in office-based settings, compared with facility settings. The policy, if implemented, would increase payment to independent practices. However, it also would reduce payment for facility-based physicians. Accordingly, the Academy urged an exemption for rural physicians and asked CMS to consider mitigating strategies to avoid penalizing those who split time between facility and non-facility settings.
3. CMS should finalize new Advanced Primary Care Management coding without cost-sharing
Following 2025’s introduction of coding to report advanced primary care management (APCM) services (based on lessons from CMS Innovation Models), the 2026 fee schedule would add APCM codes for the provision of complementary behavioral health integration (BHI) services by removing the time requirements of the existing BHI and collaborative care management services.
CMS also acknowledged feedback following last year’s rule that cost-sharing is a barrier to patient willingness to receive care management services, including APCM. The agency requested information on how it might waive APCM cost-sharing; the AAFP provided extensive comments.
4. Quality Payment Program performance threshold is unchanged
In line with the AAFP’s advocacy, the proposed rule leaves the Quality Payment Program performance threshold at 75 points through the 2028 performance year (payment year 2030). The data-completeness threshold will remain 75%, as finalized through previous rulemaking.