CMS Releases Final CY 2026 Medicare Physician Fee Schedule: Implications for Nuclear Medicine

November 4, 2025

On October 31, the Centers for Medicare and Medicaid (CMS) released its final rule for the CY 2026 Medicare Physician Fee Schedule (PFS). CMS also released a fact sheet and a press release summarizing the rule. These policies will take effect January 1, 2026, unless otherwise noted. CMS has updated addendum B RVU, and we will provide members with more information on this document shortly.

In September, SNMMI submitted detailed comments to CMS on the CY 2026 Medicare Physician Fee Schedule (PFS). Despite significant stakeholder comments, CMS largely finalized its policies as proposed, with modest adjustments to key payment reforms.

Below are key takeaways from the Final Rule.

Conversion Factors:

Consistent with requirements (by law) established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), CMS finalized the following two conversion factors (CFs) for CY 2026:

• $33.5675 for items and services furnished by Qualifying APM Participants, reflecting a 3.77% increase relative to the 2025 CF.
• $33.4009 for all other items and services, reflecting a 3.26% increase relative to the 2025 CF.
  

The SNMMI recognizes the statutory requirements that establish separate conversion factors for qualifying APM QPs and non-QPs in CY 2026. We appreciate that CMS has finalized a positive CF update for the first time in five years and welcome the one-time 2.5 percent statutory increase. However, overall payment adequacy remains a serious concern. Chronic CF declines have eroded reimbursement for nuclear medicine professionals.

Prolonged declines in the conversion factor have created financial instability for nuclear medicine and molecular imaging professionals and threaten access to essential diagnostic and therapeutic services. Accordingly, we continue to urge CMS to work with Congress to advance long-term reforms that stabilize the physician payment system and ensure updates more closely reflect practice cost growth and medical innovation.

Efficiency Adjustment:

The SNMMI is deeply concerned and disappointed that CMS finalized an arbitrary 2.5% efficiency adjustment to work Relative Value Unit (RVUs) and corresponding intra-service physician time for non time-based services beginning in CY 2026. The policy applies broadly but exempts time-based codes (e.g., E/M, care management, behavioral health), maternity codes (MMM global periods), telehealth services, and in a notable change from the proposed rule new CY 2026 codes. This means that newly established codes for CY 2026 will be exempt from the 2.5% reduction. CMS did not finalize any new nuclear medicine specific codes for 2026.

While SNMMI shares CMS s commitment to maintaining accuracy in physician payment policy, The Society cautions that applying a broad, recurring efficiency adjustment based on assumptions rather than empirical, specialty-specific data risks destabilizing access to nuclear medicine and undermining the ability of practices to provide state-of-the-art care to Medicare beneficiaries.

Indirect Practice Expense (PE) Allocation:

CMS finalized its proposal to revise how indirect practice expenses are allocated for facility-based services. Beginning in CY 2026, CMS will reduce by 50% the portion of indirect PE RVUs that are tied to work RVUs for facility settings relative to non-facility settings. This revision will slightly increase payments to office-based specialties and decrease those for facility-based specialties, without affecting the overall conversion factor.

SNMMI strongly opposed this proposal, noting that it disproportionately reduces payments for facility-based services particularly nuclear medicine without achieving CMS's stated goal of protecting private practices and preventing duplicate payments.

Merit-Based Incentive Payment System:

CMS finalized several updates to measure/activity inventories and scoring methodologies that impact different MIPS reporting pathways, including but not limited to:

• 190 total quality measures for the 2026 performance period,

• Setting of the performance threshold through the CY2028 performance period at 75 points to provide program stability,
• Implementation of five new MIPS quality measures, including three high priority measures,
• Removal of 10 MIPS quality measures,
• Substantive changes to 30 MIPS quality measures,
• Updates to the APP Plus measures set to align with the MIPS quality measure inventory,
• Modifications to the MIPS cost measure inventory,
• Updates to the operational list of care episode and patient condition groups and codes to align with changes in service and diagnosis codes used to define these groups,
• Adoption of a two-year informational-only feedback period for new cost measures, during which they will not affect MIPS cost performance category scores, final scores, or payment adjustments until the third year after introduction,

• Revision of two population-based cost measures, including Total Per Capita Cost (TPCC),

• Modification of the definition of high priority measure to remove references to health equity,
• Addition of the Advancing Health and Wellness IA subcategory, removal of the Achieving Health Equity IA subcategory, and addition of three new IAs, and
• Changes to two PI measures and addition of a new optional bonus measure: Public Health Reporting Using Trusted Exchange Framework and Common Agreement (TEFCA).

MVP Proposals

CMS previously finalized the creation of the MVP, a reporting option for MIPS intended to provide a more cohesive participation experience by aligning activities from the four MIPS performance categories around a certain specialty, medical condition, or patient population.

CMS finalizes six new MVPs for the CY 2026 performance period, including Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery. Additionally, CMS finalizes:

• Modification to all 21 existing MVPs,
• Requiring groups to attest to their specialty composition (i.e., whether they are single-specialty or multispecialty small practices) during the MVP registration process, rather than CMS making this determination,
• Allowing multispecialty small practices to report an MVP as a group, without being required to form subgroups starting in the CY 2026 performance period, and
• Giving Qualified Clinical Data Registries (QCDRs) and Qualified Registries one year after a new MVP is finalized before they are required to fully support that MVP.

SNMMI expects that CMS will release the CY 26 Hospital Outpatient Prospective Payment System (OPPS) Final Rule soon. In the meantime, the Society will continue to engage with CMS to protect fair reimbursement for nuclear medicine procedures and to advance data-driven, specialty-appropriate policies.