The Centers for Medicare and Medicaid Services (CMS) recently released the CY 2026 Physician Fee Schedule (PFS) Proposed Rule, which includes updates to the Quality Payment Program (QPP), the Merit-based Incentive Payment System (MIPS), practice expense methodology, and more.
The following summary highlights how key changes in the proposed rule will impact Anesthesia providers and practices.
Physician Fee Schedule
For the first time in six years, the Conversion Factor (CF) could increase. The proposed CY 2026 CF for Anesthesia is $20.5728 for most providers, which represents a 1.26% increase over 2025. New this year, CMS is proposing a separate CF of $20.6754 for physicians participating in Advanced Alternative Payment Models (APMs), which is 1.8% 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 0.55% positive budget neutrality adjustment
- A 2.5% one-time payment boost from the One Big Beautiful Bill Act
Efficiency Adjustment
For some physicians, a proposed -2.5% efficiency adjustment for non-time-based services could offset some of the CF benefits. CMS believes that current reimbursement rates may not reflect efficiencies gained by recent technological and operational improvements in care delivery. The proposed 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 proposes to apply the efficiency adjustment to work RVUs every three years, which will further decrease work RVUs cumulatively over time.
Practice Expense Methodology
Proposed changes to the Practice Expense (PE) portion of RVUs could also impact compensation for facility-based physicians. CMS is proposing to change 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the current methodology of allocating the same indirect PEs to both facility-based and non-facility-based physicians is outdated and doesn’t factor in the rise in employed physicians.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 proposed rule would reduce PE RVUs in the facility setting to half those for the non-facility setting.
This change obviously impacts reimbursement for Anesthesia providers. Critically, it will also impact compensation for practices that pay clinicians based on total RVUs, as a reduction in PE RVUs will bring down total RVUs.
The Cumulative Effect on Revenue
Overall, we expect to see a slight negative effect on revenue for Anesthesia. Many procedures are time-based, which will limit the impact of the efficiency adjustment, but the rebalancing of PE RVUs will likely result in a -1% shift. Also, few Anesthesia providers participate in APMs, which means most will not see benefits from the new higher CF rate for APM clinicians.
QPP and MIPS
CMS remains committed to the Quality Payment Program (QPP) and the Merit-based Incentive Program (MIPS), and they are making few substantive changes to the program.
Here’s what Anesthesia providers need to know:
Performance Thresholds and Category Weighting
- The MIPS performance threshold is proposed to remain at 75 points through CY 2028.
- The data completeness threshold is proposed to 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 are expected to remain the same for 2026.
Quality Category Updates
CMS re-evaluates the list of Quality measures annually, and they are proposing the removal of one measure from the Anesthesia set:
- QID424: Perioperative Temperature Management
The Anesthesia measure set is small, so the removal of this measure may have a negative impact on providers and groups. The remaining measures still stand, and they include:
- QID404: Smoking Abstinence
- QID430: Prevention of Post-Operative Nausea and Vomiting (PONV) – Combination Therapy
- QID463: Prevention of Post-Operative Vomiting (POV) Combination Therapy (Pediatrics)
- QID477: Multimodal Pain Management
The good news: The new 10-point scoring system introduced in 2025 for highly topped-out Quality measures will continue, and CMS is proposing this year to apply the 10-point scale to QID430, QID463, and QID477. For a more detailed explanation of the topped-out Quality measures, please read our 2025 analysis.
Cost Category Updates
A proposed change to the Total Per Capita Cost (TPCC) measure’s attribution rules may 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 is intending to change that. Moving forward, NPs and PAs who are part of a group where the rest of the clinicians are exempt from the measure will now also be exempt. (CMS should automatically make this change, and no additional work will be required during reporting.) Further, CMS proposes to implement 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.
Promoting Interoperability
PI is voluntary for most hospital-based physicians and groups, and their categories are automatically re-weighted to omit PI. However, PI scores are typically high and can offset lower Quality measures when contributed toward your final score. We recommend contacting hospital IT to request a PI report for 2026, ideally by September 2026.
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 the Anesthesia MVP. The same quality measure removed from the traditional set is being removed here, as well:
- QID424: Perioperative Temperature Management
Teaching Physician Supervision
CMS plans to end virtual supervision policies in urban areas after December 31, 2025, requiring teaching physicians to be physically present with residents during key parts of care. Exceptions will continue for some rural areas.
Next Steps
CMS is collecting feedback on the proposed rule and will release the final rule later this fall. As always, the Ventra Health team will be monitoring the changes and planning for all issues that will impact our clients. We are committed to providing the support and guidance you need to make the best decisions for your practice.
Additional information and resources are available here in our recent overview of the CY 2026 Physician Fee Schedule Proposed Rule. If you have any questions about how these changes will impact your Anesthesia group, please don’t hesitate to reach out to our team.
