Rob Blaser

More to come, Happy Halloween. (8/end).

Recall that this is the first year of the two-conversion factor system mandated by MACRA that gives a higher bonus for qualifying APM participants and a lower increase for non-qualifying Medicare Part B providers. (7)

"Similarly, the final CY 2026 nonqualifying APM conversion factor of $33.40 represents a projected increase of $1.05 (+3.26%) from the current conversion factor of $32.35.” (6)

Regarding the conversion factor, this too is unchanged from what was proposed; per the CMS press release on the rule, “the final CY 2026 qualifying APM conversion factor of $33.57 represents a projected increase of $1.22 (+3.77%) from the current conversion factor of $32.35. (5)

Accordingly, changes to the dialysis code family and to E&M codes are as proposed in July, healthy increases for outpatient E&M services/corresponding cuts to I/P E&M codes. One change made to the efficiency adjustment proposal is to exempt new codes from the adjustment. (4)

Thus, the -9.4% hit for (for example) CPT code 90935 (inpatient dialysis) and the +9.0 increase for 90960 (adult monthly dialysis) are still as proposed. (3)

So, nephrology is still slated to have a projected impact of +1%, and the inpatient/outpatient dichotomy is in July, as the methodological changes for the work RVUs (via the efficiency adjustment) and the practice expense RVUs (via changes to indirect PEs) are still in place. (2)

Folks, the final rule for the 2026 Medicare Fee Schedule was released tonight, and it appears to have been finalized almost exactly as it was proposed. (1)

The MLN post ended up being correct, CMS issued a clarification last night that aligned with the MLN post and thus the vast majority of claims will be paid as scheduled.

Great question. There was much communication (confusion?) yesterday that all payments were paused per a CMS announcement, but the original Medicare Learning Network (MLN) post said it only claims for expiring provisions were being held, like those for telehealth. (1)

Very kind Charlotte, thank you. Great seeing you and I hope you had an uneventful trip home.

@rpanephrology leaders strategizing about RPA’s Capitol Hill Day tomorrow. Over drinks.

So, given the good chance that a Medicare extenders package happens before say year's end, the flexibilities should be extended then. Stay tuned. (4/end)

Whether that lasts for days/weeks/months no one knows, but practices should be adjusting their schedules accordingly. The positive news IMO is that everyone on the Hill seems to agree that the telehealth flexibilities should be extended if not made permanent. (3)

While I was pretty bullish that this would get resolved prior to 9/30 earlier this year, now it looks pretty likely that there will be a lapse in the flexibilities with an almost certain government shutdown. (2)

Folks, there is a lot of chatter among nephrology practices about whether the telehealth flexibilities and thus the ability to provide services via those means will end on September 30. (1)

Charlotte, the chances of it getting resolved by September 30 are slim to nonexistent. My guess is the flexibilities will be extended by years’ end but when that happens, who knows?

NEPHROLOGY NURSES, YOU ROCK!!! Happy Nephrology Nurses Week to all of the heroes out there providing great care to persons with kidney disease, can't wait to spend time with our friends at the American Nephrology Nurses Association next week. Thanks for everything y'all do!

You know that scene in an action movie when the bad guy runs through the kitchen of a restaurant and pulls down all the pots and pans behind him to slow down his pursuers? We're in that part of the Trump presidency.

Folks, there was a error in my MFS post this A.M., the 'all others' CF increase for 2026 will be about $3.30, not $3.62. The 2nd figure ($3.62) was from the CMS Newsroom press release on the rule, but that's no excuse, I should have double checked the math. Sorry about that.

Comments on the proposed rule are due on September 12. (12/end).

creation of a new payment model focused on heart failure and low back pain, a change to the Medicare Diabetes Prevention Program to facilitate greater access to the program, and an effort to reduce Medicare spending on skin substitutes, among others. (11)

Those are the foundational changes this year, there are of course numerous other proposals (it's an 1800 page rule), on telehealth (but not about extension of the current flexibilities, Congress has to do that), (10)

On a code-specific level, CPT code 90935 (hemodialysis, single evaluation), is slated for a 9.4% cut, while the four visit adult outpatient dialysis capitated service (CPT code 90960) is set for a 9.0% increase. (9)

Using nephrology as an example of the impact of the RVU changes, while the specialty nets out at a +1% overall impact, on the inpatient side there is a projected 9% payment cut, while outpatient are expected to increase by 7%. (8)

$33.59 for those qualifying participants in APMs, $33.42 for all others. Recall that the 2025 CF is $32.35, so the 2026 APM-based CF will be a 3.83% increase over the 2025 CF, while the ‘all others’ CF will be increased by 3.62%. (7)

Regarding the 2026 CFs, they include a 0.75% increase for APM participants and a 0.25% increase for all others, the 2.5% increase enacted in the One Big Beautiful Bill (H.R. 1) and also an upward budget neutrality adjustment of 0.55%. All of this results in 2026 CFs of: (6)

and (2) a reduction of the the allocation of indirect costs for PE RVUs in the facility setting that CMS believes is more reflective of current medical practice. (5)

while outpatient services and primary care will see nearly equal increases in value and payment. CMS' changes that are the catalysts for these revisions are (1) use of an efficiency adjustment on work RVUs that reduces the impact of the survey process used to develop RVUs, (4)

The other big headline is that due to fundamental methodological changes affecting development and implementation of changes to relative value units (RVUs), inpatient services and many procedures will see steep reductions in value and payment in 2026, (3)