CMS Finalizes 2026 Medicare Physician Payment Updates
CMS Finalizes 2026 Medicare Physician Payment Updates
Date: November 2025 | Location: Washington, D.C.
The Centers for Medicare & Medicaid Services (CMS) has released the Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Final Rule. The companion payment updates under the Outpatient Prospective Payment System (OPPS) are still pending. Under the final rule, CMS finalized a national average payment rate of $127.20 per cm² for cellular, acellular, and matrix-like products (CAMPs), effective January 1, 2026. The OPPS is expected to align with this $127.20/cm² unit rate. In the Hospital Outpatient Department (HOPD) setting, both the product code and application code will remain separately payable. CMS has also proposed the facility application code (CPT 1527X) at $746.61, though this figure may change slightly once final OPPS Addendum B files are posted.
WHA Advocacy in Motion
Initiative & Description
Temporary Injunction
To be filed before year-end to halt implementation of CMS’s new rules under the PFS and OPPS.
Legislative Advocacy
Support for the bipartisan Skin Substitute Access and Payment Reform Act of 2025 (S. 2561 / House companion) by Sen. Bill Cassidy and Rep. Buddy Carter. The bill seeks to override CMS’s new rules and delay implementation of future CAMP LCDs for up to one year.
CMS Engagement
A formal request for a National Coverage Determination (NCD) for CAMPs will be submitted by year-end.
MAC Reconsiderations
Once CAMP LCDs take effect, wound-care provider groups across the nation will be recruited to file formal reconsideration requests with their respective Medicare Administrative Contractors (MACs).
Broader Physician Payment Updates
Beyond CAMPs, CMS’s 2026 rule includes positive conversion factor updates after a 2025 reduction. The American Medical Association (AMA) reports a 3.77% increase for Advanced Alternative Payment Model (AAPM) qualifying participants and a 3.26% increase for all other physicians, reflecting a temporary 2.5% pay bump enacted by Congress in H.R. 1. The AMA continues to advocate for permanent payment reforms that reflect rising costs.
Read the full CMS Final Rule: Federal Register Document No. 2025–19787 (https://www.federalregister.gov/documents/2025/11/05/2025-19787/medicare-and-medicaid-programs-cy-2026-payment-policies-under-the-physician-fee-schedule-and-other)