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2026 CMS Proposed Rule and Reimbursement Challenges in Emergency Medicine

The CY 2026 CMS Physician Fee Schedule proposes a conversion factor of $33.4209, a 3.3% increase over 2025 for most physicians, and $33.5875 for Advanced APM participants 1 2 . CMS proposes reducing indirect Practice Expense (PE) RVUs in facility settings to half of non-facility rates, negatively impacting emergency medicine revenue and clinician compensation based on RVUs 1 2 . Overall, emergency groups may see a 1-2% revenue increase from the conversion factor, offset by PE changes and efficiency adjustments 1 . Medicare payments for emergency care have declined 3.8% from 2018-2022, with out-of-network down 47.7% and in-network down 10.9%; longer-term, down over 30% since 2001 adjusted for inflation 2 . CMS seeks input on separate codes or add-ons for urgent care to reduce low-acuity ED visits and proposes permanent telehealth additions for ED E/M codes (99281-99285), critical care, and observation 1 . ED visits reached 139.8 million in 2024, projected to grow 5% over the n...

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