CMS finalized the CY2026 Medicare Physician Fee Schedule (PFS) in November 2025. The rule includes changes to the conversion factor, telehealth policy, behavioral health billing, and several specialty-specific payment refinements effective January 1, 2026.
Conversion factor
The CY2026 conversion factor is $32.35 — a decrease of approximately 2.8% from CY2025’s $33.29. This reflects the standard statutory update formula adjustments and the elimination of a temporary COVID-era add-on payment.
The practical impact varies by specialty: providers billing predominantly evaluation and management (E/M) codes see a smaller effective reduction than those billing procedure-heavy codes, because CMS has revalued several E/M codes upward in recent years.
Telehealth extensions
CY2026 maintains Medicare telehealth flexibilities that were extended through 2026 under the Consolidated Appropriations Act:
- Audio-only telehealth for behavioral health remains covered when the beneficiary does not have access to or is not technologically capable of using video
- Geographic and originating site waivers — patients can still receive telehealth services at home, not only at approved originating sites
- Mental health services via telehealth continue to be available without an in-person visit requirement during 2026
⚠️ Risk flag: These flexibilities are statutory extensions, not permanent policy. Providers building telehealth workflows should monitor Congressional action closely — if the extensions are not renewed beyond 2026, telehealth billing reverts to pre-COVID restrictions requiring rural originating sites.
Behavioral health billing changes
CY2026 adds new codes and refines existing codes for:
- Behavioral health integration (BHI) services — new care management codes for collaborative care model (CoCM) and psychiatric collaborative care
- Crisis stabilization services — new codes for intensive outpatient behavioral health crisis stabilization, relevant to LMHCs, LCSWs, and MFTs newly enrolled in Medicare
- Marriage and Family Therapists (MFTs) — now able to bill independently under Medicare Part B with new provider taxonomy recognition
Therapy-specific changes
Physical therapy, occupational therapy, and speech-language pathology providers should note:
- Functional reporting — Medicare eliminated separate functional limitation reporting requirements years ago, but some MACs have updated their documentation checklists; review your MAC’s local coverage determination (LCD) for any updates
- Supervised exercise therapy (SET) — coverage for patients with peripheral artery disease (PAD) expanded; applicable PT practices should review billing requirements
- MIPS reporting — therapy providers meeting the low-volume threshold exemption ($90,000 Medicare Part B charges or ≤200 Medicare patients) are not required to participate in MIPS
What to do
- Review your top 20 billed CPT codes against the CY2026 fee schedule to identify net revenue impact
- If you bill behavioral health codes, review the new BHI and crisis stabilization codes for applicability
- If you provide telehealth, document your billing policies against the current extension terms
- Ask Mae to help identify which changes affect your specific provider type
CMS posts the full fee schedule files at the CMS website; your MAC’s education newsletter typically publishes a specialty-specific summary within 30 days of the final rule.