CMS Finalizes Policies Undermining Anesthesia Payments and Ability for Anesthesiologists to Meaningfully Participate in the Quality Payment Program

On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) final rule, which includes policies related to Medicare physician payment and the Quality Payment Program (QPP). While the One Big Beautiful Bill Act (OBBBA) introduced a 2.5% increase to the conversion factor methodology, CMS approved policies affecting other components of the methodology that wiped out a large portion of what was provided by the OBBBA, resulting in a meager 0.88% conversion factor update for most anesthesiologists. Such policies will not improve the financial strain that anesthesia groups are facing. 

Unless otherwise noted, payment and regulatory policies will be effective on January 1, 2026.

The final rule underscores how the Medicare payment system is broken, especially during a time when anesthesia groups are faced with multiple financial and economic pressures. ASA will continue to engage legislative stakeholders and regulatory agencies to address such a negative impact on anesthesiologists.

Fee Schedule Provisions:

CY 2026 will be the first year that the PFS conversion factor (CF) will differ based on whether qualified clinicians are participating in an Advanced Alternative Payment Model (APM). MACRA provides for a 0.75% base payment update for items and services furnished by Qualifying APM Participants and a 0.25% base payment update for other items and services. As a result, the 2026 anesthesia CF is:

• $20.5998 for items and services furnished by Qualifying APM Participants, representing a 1.39% increase from the 2025 anesthesia CF of $20.3178.
• $20.4976 for other items and services, representing a 0.88% increase from the 2025 anesthesia CF.

The proposed 2026 RBRVS CF is:

• $33.5675 for items and services furnished by Qualifying APM Participants, which reflects a 3.77% increase relative to the 2025 CF.
• $33.4009 for other items and services, which reflects a 3.26% increase relative to the 2025 CF.

The change to the PFS CF incorporates several factors:

• A statutory annual update of +0.75% for items and services furnished by Qualifying APM Participants and an update of +0.25% for other items and services, as authorized under MACRA.
• A +0.49% budget neutrality adjustment, required by law, to offset changes in work Relative Value Units (RVUs) for some services. This means spending in one year needs to be balanced by reductions and CMS cannot increase or decrease expenditures by more than $20 million without triggering automatic budget neutrality adjustments.
• A temporary +2.5% increase in physician payments for 2026, authorized in the recent budget reconciliation package, One Big Beautiful Bill Act (H.R. 1). As a reminder, physician payments were reduced by 2.83% in 2025 after a temporary increase in payments for 2024 expired.
• A -2.3% across-the-board cut to the anesthesia CF for practice expense and malpractice insurance. ASA argued against this reduction, noting CMS was not transparent in how the figure was calculated. The cut also undermined expected increases passed through the OBBBA.
• CMS finalized its policy to shift a significant portion of indirect practice expense payments from the facility to the non-facility setting.
• CMS finalized an efficiency adjustment of -2.5% to the work RVUs and corresponding intraservice portion of physician time of non-time-based services for services that CMS expects to accrue gains in efficiency over time. ASA and other medical specialties were opposed to such arbitrary cuts in payments noting CMS provided little detail or transparency in their proposal. 

Specialty Impact on Anesthesia and Pain Medicine

Actual payment rates are impacted by a range of proposed policy changes related to physician work, practice expense, and malpractice RVUs. CMS estimated these changes in Table D-B7 of the final rule. Impact by practice will vary based on service mix. The table indicates that the impact of policies in the proposed rule will have on anesthesiology and interventional pain management.

Note, changes to the CF are not reflected in the impact table. The figures below are CMS estimates.

Source: Table D-B7, CY 2026 PFS final rule, display copy

Because CMS finalized its proposal to shift a significant portion of indirect practice expense payments from the facility to the non-facility setting, the published table includes changes for anesthesiologists and other specialties based upon their charges in facility and non-facility settings.

Pain Medicine Code Updates

We are happy that CMS accepted the RUC recommendation for the newly created Percutaneous Image-Guided Lumbar Decompression (PILD) for Lumbar Spinal Stenosis codes. Starting January 1, 2026, pain medicine physicians will be able to get paid by Medicare for Lumbar Decompression services using the new category I PILD CPT codes (62330 and 62331). For CY 2026, CMS has proposed the following work RVUs for the PILD codes, which are the same as the RUC recommended value. The table below reflects CMS’s proposed work RVUs for the fascial plane block codes.

Please contact [email protected] with any questions related to the Medicare Physician Fee Schedule.

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Quality Payment Program Provisions:

CMS also released its 2026 Quality Payment Program (QPP) policies. The proposed rule provides details on how eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models and other features of the QPP during the 2026 performance year.

For the 2026 reporting year.

• CMS finalized the MIPS performance threshold at 75 points through CY 2028. Scoring below 75 points would result in a payment penalty in 2028.
• By law, the weights of the different MIPS requirements will not change: the quality performance category will be weighted at 30% and the cost performance category will be weighted by 30%. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.
• CMS removed QID424: Perioperative Temperature Management from the MIPS program, citing its topped-out status as the reason. The CMS decision will likely increase burdens on anesthesia groups as they seek to report other quality measures. 
• CMS will maintain the data completeness threshold for the MIPS Quality Performance Category at 75% for the 2026 through 2028 performance years.
• CMS finalized adding three anesthesiology quality measures to alternative benchmarking (QID430, QID463, QID477).

Anesthesiologists will continue to have the opportunity to report the Anesthesiology MIPS Value Pathway in 2026. MIPS Value Pathways (MVP), CMS believes, will alleviate some of the reporting burdens that anesthesiologists and other physicians encounter in the MIPS program. For 2026, CMS has removed two quality measures from the MVP:

• QID424: Perioperative Temperature Management
• QID487: Screening for Social Drivers of Health

CMS removed two Improvement Activities from the MVP:

• IA_CC_2: Implementation of improvements that contribute to more timely communication of test results
• IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B. 

CMS finalized its Ambulatory Specialty Model (ASM), a mandatory model that was developed based on the MVP framework. The model, which would run from 2027 to 2031, targets specialists who frequently treat low back pain or heart failure in selected geographic areas. Eligible physicians, including anesthesiologists and pain management providers, will be assessed individually and subject to performance-based payment adjustments ranging from -9% to +9% in the first year. ASA and other medical specialties opposed this model, citing the lack of applicable quality measures for anesthesiologists among other reasons.

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].

ASA leaders and staff will review the rule and release additional information in the coming weeks. Unless otherwise noted, finalized provisions will become effective on January 1, 2026.

For more information:

• Final Rule Text 
• CMS Press Release 
• CMS Fact Sheet on the Medicare Shared Savings Program (MSSP)  
• CMS Fact Sheet on the Medicare Physician Fee Schedule