2026 CMS Final Rule: Impacts on Radiology

The Centers for Medicare and Medicaid Services (CMS) recently released the CY 2026 Physician Fee Schedule (PFS) Final Rule, which includes updates to the Quality Payment Program (QPP), the Merit-based Incentive Payment System (MIPS), practice expense methodology, telehealth reimbursement, and more.

The key takeaway for Radiology: CMS’ estimated overall impact of the 2026 changes will vary across Radiology specialties. We expect to see a -2% negative effect on revenue for Diagnostic Radiology, a -1% impact for Nuclear Medicine and Radiation Oncology, and a +2% impact for Interventional Radiology. Included in those assessments is a significant variance that now falls between facility-based and non-facility-based providers. We expect a decrease across facility-based charges, but an increase across non-facility charges.

Bottom line, the 2026 final rule will impact individual practices very differently depending on their specialty, where they deliver services, and the specific CPT codes they are charging.

The following summary provides the detail behind those conclusions, as well as the specifics on how changes in the final rule will affect radiologists and their practices.

Physician Fee Schedule 

The CY 2026 Conversion Factor (CF) increased, but not by as much as suggested in the proposed rule. The final CY 2026 CF is $33.4009 for most physicians, which represents a 3.26% increase over 2025. New this year, CMS finalized a separate CF of $33.5675 for physicians participating in Advanced Alternative Payment Models (APMs), which is 3.77% more than the 2025 rate.

The increases are based on three factors:

• A statutory increase in the Medicare Access and CHIP Reauthorization Act (MACRA) of 0.25% for non-APMs and 0.75% for qualifying APMs
• A 0.49% positive budget neutrality adjustment
• A 2.5% one-time payment boost from the One Big Beautiful Bill Act

Efficiency Adjustment 

CMS is imposing a -2.5% efficiency adjustment that will cut RVUs for non-time-based services and will offset some of the CF benefits for Radiology providers and groups. CMS believes that current reimbursement rates may not reflect efficiencies gained by recent technological and operational improvements in care delivery. The efficiency adjustment, based on a five-year review of Medicare Economic Index (MEI) productivity data, is intended to correct for the issue by lowering work RVUs and making corresponding updates to the intraservice portion of physician time inputs for certain services. CMS will apply the efficiency adjustment to work RVUs every three years, which will further decrease work RVUs cumulatively over time.

Practice Expense Methodology

Changes to the Practice Expense (PE) portion of RVUs will also impact revenue for radiologists and other facility-based physicians. CMS is changing the way it allocates indirect PE RVUs, which reflect the administrative overhead of running a practice. (Direct PE RVUs were already calculated differently for facility-based physicians.) CMS believes the current methodology of allocating the same indirect PEs to both facility-based and non-facility-based physicians is outdated and doesn’t factor in the rise in employed physicians. The CY 2026 final rule reduces indirect PE RVUs in the facility setting to half those for the non-facility setting. This will not apply to services with the 26 modifier.

This change obviously impacts reimbursement for radiologists. Critically, it will also impact compensation for practices that pay clinicians based on total RVUs, as a reduction in indirect PE RVUs will bring down total RVUs.

The Cumulative Effect on Revenue

Again, we expect the overall effect of these three changes to vary across Radiology specialties, ranging from -2% for Diagnostic Radiology, -1% for Nuclear Medicine and Radiation Oncology, and +2% for Interventional Radiology. The benefit radiologists and groups will get from the general CF increase will be offset by both the efficiency RVU cuts and the rebalancing of indirect PE RVUs that disproportionately affect facility-based and non-time-based services.

The following chart shows expected revenue impact across both specialties and settings.

Telehealth Reimbursement 

CMS has streamlined telehealth service review, removing the distinction between provisional and permanent telehealth services and focusing only on whether the services can be delivered via two-way, real-time audio-video technology. CMS has also permanently removed frequency limits on telehealth for inpatient, nursing facilities, and critical care visits. Virtual supervision is now permanently allowed for services requiring direct oversight.

Teaching Physician Supervision

CMS ended virtual supervision policies in urban areas after December 31, 2025, requiring teaching physicians to be physically present with residents during key parts of care. However, virtual supervision in teaching settings is now permanently permitted when the service itself is furnished virtually.

Direct Supervision 

Direct supervision may be met via real-time audio-visual communication (not audio-only) for applicable incident-to services, diagnostic tests, pulmonary rehabilitation, cardiac rehabilitation, and intensive cardiac rehabilitation. This does not include services with global surgery indicators 010 or 090.

QPP and MIPS 

CMS remains committed to the Quality Payment Program (QPP) and the Merit-based Incentive Program (MIPS), and they have made few substantive changes to the program that will affect Radiology. As CMS has expressed that MVPs will soon become the standard, CMS is finally adding two MVPs for Radiology.   

Here’s what Radiology practices and providers need to know: 

Traditional MIPS Performance Thresholds and Category Weighting

• The MIPS performance threshold will remain at 75 points through CY 2028.
• The data completeness threshold will remain at 75% for the MIPS Quality Performance Category through the CY 2028 performance period, possibly rising to 80% in CY 2029.
• There are no expected overall changes to the 2026 weighting of the four reporting categories: Quality, Improvement Activities, Cost, and Promoting Interoperability. However, qualifying for a Special Status (small, non-patient-facing, etc.) will continue to affect the weighting of categories for individuals or groups. Check your Special Status when it becomes available in December 2026 to see what may be re-weighted.
• Eligibility criteria for individuals will remain the same for 2026.

Traditional MIPS Quality Category Updates
CMS re-evaluates the list of Quality measures annually, and there is only one change that could affect some Radiology groups.

• Measure 322 – Cardiac Stress Imaging Not Meeting Appropriate Use Criteria has been finalized for removal in the 2026 PY.

The new 10-point scoring system introduced in 2025 for highly topped-out Quality measures will continue, and they still cover all the topped-out Diagnostic Radiology measures:

• QID360 – OPEIR: Count of Potential High Dose Radiation Imaging Studies: Computed Tomography (CT) and Cardiac Nuclear Medicine Studies
• QID364 – OPEIR: Appropriateness: Follow-up CT Imaging for Incidentally Detected Pulmonary Nodules According to Recommended Guidelines
• QID405 – Appropriate Follow-up Imaging for Incidental Abdominal Lesions 
• QID406 – Appropriate Follow-up Imaging for Incidental Thyroid Nodules in Patients 

For a more detailed explanation of the topped-out Quality measures, please read our 2025 analysis.

Cost Category Updates 
A change to the Total Per Capita Cost (TPCC) measure’s attribution will positively impact facility-based groups with nurse practitioners (NPs) and physician assistants (PAs). Historically, groups with a Special Status that exempted them from this Cost measure were seeing negative impacts when an NP or PA that didn’t qualify for Special Status inadvertently triggered the Cost measure for the whole group.

CMS changed that, which is a major win for Radiology groups. Moving forward, NPs or PAs who are part of a group where the rest of the clinicians are exempt from the measure will now also be exempt. Further, CMS has implemented a new two-year feedback-only period for new Cost measures, which will allow clinicians to review and improve without penalty before the measure officially kicks in.

MIPS Value Pathways (MVPs)
CMS is signaling that MIPS Value Pathways (MVPs) will be important in the future, although providers still have the option to report in either Traditional MIPS or an MVP. The six new MVPs for 2026 include the first-ever MVPs for Radiology and Pathology. The full list includes: Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery.

The Diagnostic Radiology MVP is divided into three clinical categories:

1. General Diagnostic Radiology, which encompasses a wide range of imaging services across various organ systems.
2.  Body Imaging (Thoracic/Abdominal), which focuses on advanced imaging techniques, including CT, MRI, and ultrasound, for thoracic and abdominal conditions.
3. Advancing Health and Wellness, which emphasizes preventive imaging, screening, and population health initiatives.

The Interventional Radiology MVP includes four clinical groups:

1. Vascular, involving procedures such as angioplasty, stenting, and embolization.
2. Dialysis-related, involving interventions related to vascular access for dialysis patients.
3. Neurological Intervention, focusing on image-guided procedures for conditions such as stroke, aneurysms, and other neurovascular issues.
4. General Interventional Radiology, which includes procedures not included in the other groups.

Each clinical category is associated with a set of quality measures, cost measures, and improvement activities that the CMS considers most relevant to the services delivered by Radiology providers. These measures assess the appropriateness of imaging, patient safety, care coordination, and participation in clinical data registries.

For more information, read this summary from the American College of Radiology.

Next Steps

The Ventra Health team is committed to providing the support and guidance you need to make the best decisions for your practice. For specific analysis on how these changes will impact your reimbursement and revenue, please reach out to us.

Read more about the CY 2026 Medicare Physician Fee Schedule Rule on the CMS Fact Sheet.