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 participants12.

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 RVUs12.

Overall, emergency groups may see a 1-2% revenue increase from the conversion factor, offset by PE changes and efficiency adjustments1.

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 inflation2.

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 observation1.

ED visits reached 139.8 million in 2024, projected to grow 5% over the next decade amid rising acuity and primary care access issues3.

Sources:

1. https://ventrahealth.com/blog/2026-cms-proposed-rule-impacts-on-emergency-medicine/

2. https://www.healthcaredive.com/spons/emergency-medicine-reimbursement-in-2026-navigating-a-system-under-pressur/807816/

3. https://emergencyservicespc.com/emergency-medicine-in-2026-trends-shaping-the-specialty/