Despite a one-time pay increase, newly proposed adjustments in the 2026 Medicare physician fee schedule could offset the reprieve. The concern tops many the Texas Medical Association remarked upon in a lengthy comment letter to federal officials encompassing worrisome changes to Medicare payment, certain quality payment programs, and telemedicine flexibilities.
TMA’s Sept. 12 letter to the Centers for Medicare & Medicaid Services (CMS) acknowledges a one-year, positive 2.5% adjustment to Medicare payment following five consecutive years of Medicare payment reductions, plus an additional 0.75% increase for qualifying alternative payment model (APM) participants and 0.25% increase for non-qualifying APM participants.
Still, TMA repeated its call for permanent reform to Medicare physician payment, citing the American Medical Association’s calculation those payment rates have declined 33% from 2001 to 2025 when adjusted for inflation.
“The fact that it’s only a one-year fix means we have to do this all over again in six months,” said Michelle Berger, MD, chair of TMA’s Texas Delegation to the AMA. “The frustration level amongst physicians is just getting really, really high.”
TMA also points out the newly proposed rule includes a 2.5% practice efficiency cut that “would reduce payment for 8,961 non-time-based physician services.” Dr. Berger, citing AMA’s deep dive on the numbers, observes the proposed practice efficiency cut could create an overall reduction in Medicare payment for affected physician specialties, even when figuring in the 2.5% bump.
The practice efficiency cut directly impacts work relative value units (RVUs), part of the payment equation that, per AMA, measures “a physician’s time, technical skill, mental effort, decision-making, and stress.”
CMS explained in its proposed physician fee schedule fact sheet that while it previously based work RVUs on survey data from the AMA Relative Value Scale Update Committee (AMA RUC), many service codes in use are now “very likely overinflated,” and the agency proposed the practice efficiency cut to address that.
TMA counters that CMS should continue to rely on AMA’s data for determining work RVUs.
“The AMA has been doing this for 30 years, and we have confidence in the way we do it,” said Zeke Silva, MD, who chairs both TMA’s Council on Legislation and the AMA RUC.
TMA also opposed CMS’ proposed 50% indirect expense cut, which AMA predicts will decrease payment for physicians providing services in certain facilities by 7% overall.
Beyond payment, TMA is monitoring developments around CMS’ Quality Payment Program (QPP).
TMA supports the overall goals of QPP and appreciates CMS’ decision to limit the number of proposed policy changes for 2026 to focus on stability in the program. Frequent changes to reporting, participation, and other requirements add unnecessary complexity and confusion for physicians.
Despite these efforts, TMA remains deeply concerned physicians participating in the Merit-Based Incentive Payment System (MIPS) and MIPS Value Pathways (MVPs) continue to face steep penalties – up to 9% of their Medicare payments – without evidence the program delivers meaningful improvements in patient care. The recently released 2023 QPP participation and performance results highlight MIPS disproportionately penalizes small, rural, and independent practices, along with the vulnerable patients they serve.
Also troubling, MIPS participants who achieved a perfect score of 100 points received only a 2.15% adjustment in 2025, an increase that does not cover the cost of compliance, which findings in JAMA Health Forum place at $12,800 per physician on average.
Even with its flaws, TMA believes CMS must not phase out traditional MIPS in favor of MVPs, which has not been proven equitable, sustainable, and workable for practices of all sizes. Meanwhile, the agency, looking to encourage MVP participation, has expanded the program’s specialty options with six new paths, culminating in a total of 27 specialties in the 2026 performance year.
TMA also argues CMS must not base new payment models on MVPs, such as the newly introduced an ambulatory specialty model (ASM) program aiming to incentivize specialists for proactive care of chronic conditions like heart failure and low back pain. It remains unknown whether Texas physicians will be included in the program, which starts Jan. 1, 2027, and runs through Dec. 31, 2031.
While TMA lauds CMS for recognizing the role of specialists in prevention and chronic care management, the ASM “relies on the flawed Merit-Based Incentive Payment System (MIPS)/MIPS Value Pathways (MVP) framework, which is complex, administratively burdensome, and has shown little evidence of improving quality or reducing costs.”
Given the very limited uptake of MVP reporting, which was introduced only in 2023, TMA warns building the ASM on such a narrow and untested foundation risks undermining physician confidence and discouraging participation.
TMA urges CMS to delay implementation of the ASM program until MVP experience is better able to inform well-designed programs that inspire, rather than mandate, specialist engagement while delivering real value to Medicare beneficiaries.
CMS has done work to help physicians find success with telemedicine, however, by introducing new services and add-on codes and removing certain frequency limitations. But TMA calls on CMS to extend the waiver allowing physicians to use their enrolled practice locations rather than their home address while practicing telemedicine at home.
Additionally, geographic-site restrictions that allow beneficiaries to receive care in their homes are set to expire on Sept. 30 unless Congress acts.
Although not officially part of the proposed 2026 Medicare physician fee schedule, TMA also took the opportunity in its letter to implore CMS to pause implementation of the Wasteful and Inappropriate Service Reduction Model pending additional stakeholder input, more thorough analysis, and clearer guidelines for physicians and patients.
Read about how recent federal legislation may impact physicians now and in the future, and learn more about TMA’s federal advocacy.
Phil West
Associate Editor
(512) 370-1394
phil.west[at]texmed[dot]org
Phil West is a writer and editor whose publications include the Los Angeles Times, Seattle Times, Austin American-Statesman, and San Antonio Express-News. He earned a BA in journalism from the University of Washington and an MFA from the University of Texas at Austin’s James A. Michener Center for Writers. He lives in Austin with his wife, children, and a trio of free-spirited dogs.