Aug 21, 2026 · 42 min · 11 segments
The Centers for Medicare and Medicaid Services (CMS) has announced more concerning proposals that will affect access to care and reimbursement. Host Dr. Andrew Pouw reconvenes last year's guests from…
Brandi KeysGuest
Andrew PauHost
John McAllisterGuest
Rebecca HeiderGuest
While we're here, um, John, Rebecca, and Brandy, for all of you, I wonder, 'cause I'm sure our listeners, you know, it's-- it, it boggles the mind how we're talking about this again after last year when the cuts were already kind of, uh, unprecedented then, and then they're adding on top of it.
Um, I wonder if, um, the three of you can help kinda give our listeners a little bit of a high-level overview of how this year's cut is a bit different than last year's, and then where we, where we got to our efforts in addressing it.
Because I know, uh, fortunately, a lot of folks did listen to that episode last year, not really the way I wanted to get popularized.
Well, I can start off if we want to talk about the twenty twenty-six proposals that got finalized.
Um, so the, the things that, that come to mind, um, from last year's episode is that, uh, negative two point five percent cut to work RVUs for non-time based codes, and that essentially meant all procedures, imaging.
Um, and then the second policy that comes to mind that was, um, very significant for ophthalmology and specialty care in particular, were the changes that were made to the indirect practice expense for services provided in the facility setting.
Um, unfortunately, both of those policies were finalized in the proposed rule, or it-- for twenty twenty-six.
Um, and they essentially get built into-- baked into the baseline, so they persist within the twenty twenty-seven proposed rule as well.
They're not happening again, so you're not getting hit, uh, like a, a compounded, uh, negative two point five percent, but it's already been taken out of that work RVU, uh, for twenty twenty-seven proposed rule.
So I, I'd say the other thing is that the one positive thing that I think we got done early last year that we normally do is Congress recognized that there was issues with the Medicare payment system, and they did proactively enact a two point five percent boost, um, to the conversion factor for twenty twenty-six.
But then the f- the rule was finalized, and then we have the efficiency policy that just sort of took that two point five and sort of wiped it out.
So we did a lot of advocacy, and our members really were really tremendous in getting engaged in trying to educate Congress on the fact that, you know, you gave us this, l- you know, two point five percent boost, and now the, the rule is gonna take it away.
And, you know, we were really hoping to get Congress to, you know, maybe pause the, um, enact or implementation of the, uh, efficiency adjustment policy and the indirect policy before the end of last year.
And that didn't happen, but I think, you know, the positive is that Congress still did listen to what we were saying, and we did get legislation introduced earlier this year to address the efficiency adjustment that, you know, put that pause on that two point five percent.
And that was important because, you know, Con-- or CMS said they were gonna, you know, revisit this, like, every three years.
And so that would, you know, prevent, you know, us from having to face that again in another couple of years.
So, you know, we're now looking at the twenty twenty-seven rule, so, you know, we have a whole new set of issues to be working with Congress on.
While we're here, um, John, Rebecca, and Brandy, for all of you, I wonder, 'cause I'm sure our listeners, you know, it's-- it, it boggles the mind how we're talking about this again after last year when the cuts were already kind of, uh, unprecedented then, and then they're adding on top of it.
Um, I wonder if, um, the three of you can help kinda give our listeners a little bit of a high-level overview of how this year's cut is a bit different than last year's, and then where we, where we got to our efforts in addressing it.
Because I know, uh, fortunately, a lot of folks did listen to that episode last year, not really the way I wanted to get popularized.
Well, I can start off if we want to talk about the twenty twenty-six proposals that got finalized.
Um, so the, the things that, that come to mind, um, from last year's episode is that, uh, negative two point five percent cut to work RVUs for non-time based codes, and that essentially meant all procedures, imaging.
Um, and then the second policy that comes to mind that was, um, very significant for ophthalmology and specialty care in particular, were the changes that were made to the indirect practice expense for services provided in the facility setting.
Um, unfortunately, both of those policies were finalized in the proposed rule, or it-- for twenty twenty-six.
Um, and they essentially get built into-- baked into the baseline, so they persist within the twenty twenty-seven proposed rule as well.
They're not happening again, so you're not getting hit, uh, like a, a compounded, uh, negative two point five percent, but it's already been taken out of that work RVU, uh, for twenty twenty-seven proposed rule.
So I, I'd say the other thing is that the one positive thing that I think we got done early last year that we normally do is Congress recognized that there was issues with the Medicare payment system, and they did proactively enact a two point five percent boost, um, to the conversion factor for twenty twenty-six.
But then the f- the rule was finalized, and then we have the efficiency policy that just sort of took that two point five and sort of wiped it out.
So we did a lot of advocacy, and our members really were really tremendous in getting engaged in trying to educate Congress on the fact that, you know, you gave us this, l- you know, two point five percent boost, and now the, the rule is gonna take it away.
And, you know, we were really hoping to get Congress to, you know, maybe pause the, um, enact or implementation of the, uh, efficiency adjustment policy and the indirect policy before the end of last year.
And that didn't happen, but I think, you know, the positive is that Congress still did listen to what we were saying, and we did get legislation introduced earlier this year to address the efficiency adjustment that, you know, put that pause on that two point five percent.
And that was important because, you know, Con-- or CMS said they were gonna, you know, revisit this, like, every three years.
And so that would, you know, prevent, you know, us from having to face that again in another couple of years.
So, you know, we're now looking at the twenty twenty-seven rule, so, you know, we have a whole new set of issues to be working with Congress on.
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