Empowering Value-Based Care in Geriatric Health

Navigating the CY 2026 Medicare Physician Fee Schedule: Key Updates for Geriatric Care Providers

Each year the Centers for Medicare and Medicaid Services (CMS) release updates impacting payment, service options and program participation for Medicare Part B covered services in the Physician Fee Schedule Final Rule. 

Ambulatory care providers across various venues of care all rely on these updates to plan for the upcoming year. Informed providers pay close attention to how the changes affect their workflows and compensation. 

The current administration is focused on fraud, waste and abuse across the entire federal government. Healthcare is no exception. This year’s physician fee schedule addresses some of those areas where they believe they can lower the waste in spending. 

Reduction of the Facility PE RVU 

CMS has finalized a proposed update to the Practice Expense (PE) to reduce the portion of the facility PE Relative Value Unit (RVU) allocated based on work RVUs to half of the amount allocated to the non-facility PE RVUs starting in 2026. CMS indicates the updates to the payment methodology will result in more accurate valuations across all settings and better recognize the cost of care for non-facility settings. This change is designed to be budget neutral, and CMS will continue to monitor the impact on physicians and other practitioners.  

Simply put, this update will result in a decrease in reimbursement for Medicare Part B services for Skilled Nursing Facilities (POS 31) which are classified as a “facility setting” due to the fact that CMS is indicating the reduction in amount of indirect expenses applied to the PE RVUs in these settings. The offset here is for those billing the Nursing Facility setting (POS 32) as that is a non-facility based setting classification. For these settings practitioners will expect an increase in their Medicare Part B payment for services rendered. 

Medicare Shared Savings Program 

This year’s rule finalized some big changes to the Medicare Shared Savings Program (MSSP) participation. From faster timelines for hitting two-sided risk, to beneficiary count adjustments for new Accountable Care Organization (ACO) programs, this rule made some changes that will affect the program direction. 

CMS has finalized participation in a one-sided risk model to an ACO’s first agreement period to be limited to 5 years. After that ACOs will need to adopt two-sided risk agreements. The final rule also outlined that new ACO’s can drop below the 5,000 beneficiaries requirement in the first two benchmark years if they are participating in the BASIC track. 

These updates alter the structure of ACOs who are joining in the shared savings program and provides time to build process and care to ensure success in the higher risk model tracks. 

Next, CMS finalized a few changes to the primary care services that will be used in beneficiary assignment, and revised the quality performance standard and reporting requirements. CMS removed the health equity adjustment applied to the ACO’s quality score, and removed the quality measure of 487 Screening for Social Drivers of Health. 

The primary care services that will be used for beneficiary assignment include the list of HCPCS and CPT codes under 42 CFR 425.400(c)(1)(ix), as well as the Enhanced Care Model Management Services (G0568, G0569, and G0570). These additional Enhanced Care Model Management Service codes may impact assignments starting in 2026, and so you should review your organization’s use of these to see if they will help add beneficiaries to your ACO. 

Updates to the Quality Payment Program (QPP)

QPP is in the beginning stages of shifting away from its foundational setup. Beginning with performance year 2024 and payment year 2026 QPP is beginning to split the conversion factor amount applied to services. For those who are fully qualified participants (QPs) in an Alternative Payment Model (APM) program they will have a .75% increase in their conversion factor as everyone else will only have a .25% increase. This will begin to make Advanced APMs become more lucrative as the conversion factor is applied to all Medicare Part B RVU payments. 

Along with the incentive to move towards APMs, CMS is also stating the Traditional Merit-based Incentive Payment System (MIPS) program will begin to sunset in the future. This program is set to be replaced with MIPS Value Pathways (MVPs), as CMS wants to compare value based performance based on conditions that clinicians treat in their normal course of business. The Traditional MIPS program lumps all clinicians into a large group and then aligns payment adjustments based on performance across various quality measures, cost measures, and other category measures. Meeting these measures can vary based on the specialty type of practice and value performance is therefore not comparable. 

For Post-Acute Long Term Care (PALTC) facilities and clinicians the MVP that aligns with care providers is the “Value in Primary Care” MVP (M0005), which focuses on quality of care to reduce patient’s risk of diseases, disabilities, and death. The final rule has two updates to this program in 2026. The removal of Quality Measure 487: Screening for Social Drivers of Health, and removing 4 Improvement Activities: 

1. IA_AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols


2. IA_AHE_12: Practice Improvements that Engage Community Resources to Address Drivers of Health


3. IA_CC_2: Implementation of improvements that contribute to more timely communication of test results


4. IA_PM_26: Vaccine Achievement for Practices Staff: COVID-19, Influenza, and Hepatitis B

Clinicians who are participating in QPP using this MVP and using these measures that are going to be removed in 2026 performance year will need to look for and adopt new measures to meet the requirements of 4 quality measures (one of which is an outcome measure), and an improvement activity, along with the other categories that remain consistent for the next performance year. Plan ahead and continue to look at MVPs as a viable option beginning in 2026 and find improvements year over year to be ready for the full switch when CMS officially sunsets the Traditional MIPS program. 

Certification Updates to HTI-1 (Enforcement Discretion) 

November 24, 2025 the Assistant Secretary for Technology Policy and Office of the National Coordinator (ASTP/ONC), released an updated enforcement discretion to the Certification Criteria Compliance Dates impacting the updates to Health Data, Technology, and Interoperability (HTI) first iteration move that was set for January 1, 2026. With the close of the United States Government from October 1, through November 12, 2025 the certification tools that Electronic Healthcare Record vendors relied on to certify were offline and unavailable. ASTP/ONC recognized this lapse in the ability to comply with the regulations, and therefore issued an enforcement discretion through March 1, 2026 to have updated certification criteria for HTI-1. This additional time for certification means your upgrades to this new platform will now not be required until March of 2026. We still recommend you communicate with your EHR vendor and work through upgrade schedules to ensure you will be on this new platform in time for 2026 performance year requirements.