HFMA Comments on Revisions to Payment Policies under the CY 2026 Medicare PFS, Quality Payment Program and Other Revisions to Part B

In a September 10, 2025, letter to CMS, HFMA submitted comments pertaining to Proposed Rule CMS-1832-P Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2026. HFMA evaluates all payment proposals against its five principles of an effective payment system: quality, alignment of incentives, fairness and sustainability, simplification, and societal benefit.

In the letter, HFMA’s recommendations pertained to:

• New Efficiency Adjustment to Work RVUs & Intraservice time
• Practice expense (PE) Methodology: Site of Service Payment Differential