08/20/2025

2026 Proposed Physician Fee Schedule: COA’s Initial Reaction and Analysis

Earlier this month, the Centers for Medicare & Medicaid Services (CMS) released its proposed rule for the 2026 Medicare Physician Fee Schedule (PFS). The Community Oncology Alliance (COA) has completed a detailed analysis of the data using our proprietary COAnalyzer tool, which models Relative Value Units (RVUs), Geographic Practice Cost Index (GPCI), and conversion factor changes.

Encouraging Signs – With Caution
Unlike recent years of the PFS, there is good news for 2026 in the form of modest but meaningful increases across many Current Procedural Terminology (CPT) codes. While this shows CMS and the Administration moving in the right direction of properly paying community oncology for the value we deliver, there are still several years of payment cuts from previous administrations and inflation to make up for.

Most urgently, COA is deeply alarmed by the proposal to include Maximum Fair Price (MFP) under the IRA in the calculation of Average Sales Price (ASP). This change would destabilize the ASP system and cause severe cuts to reimbursement for physician-administered drugs. This is a major policy mistake that must be fixed before it causes lasting damage to patient access and the stability of the nation’s cancer system.

Overall Medicare Reimbursement Increasing
For the first time, the PFS includes dual conversion factors – one for clinicians participating in qualifying Alternative Payment Models (APMs), such as the Enhancing Oncology Model (EOM), and one for those who are not.

Looking at the numbers, with national averages and assuming no GPCI floor extension, practices not in a qualifying APM could see a 6.71% overall increase in Medicare reimbursement. Practices participating in qualifying APMs could see a 7.25% increase.

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