While the initial impression of the Medicare Physician Fee Schedule (MPFS) Proposed Rule for 2026 was an increase of 3.83% or 3.32% depending upon a physician’s APM status, the real story is told by doing further analysis. We performed a volume-weighted analysis^[i] for a composite sample practice using volumes from our database.

Overall, the professional component reimbursement for diagnostic radiology in our sample practice is estimated to increase by only 1.10% while global reimbursement for diagnostic radiology is estimated to increase only 2.00% from 2025 levels, based on the same volume of services. Interventional radiology was not included in our analysis because some CPT codes have been removed without information as to their replacement. The estimates included in the Proposed Rule were a decrease of 3% for the professional component and an increase of 1% for global reimbursement.

This is the breakdown of our analysis by modality:

* PET scan reimbursement is set at the local carrier level for global billing. That data is not available currently and so global PET was eliminated from the analysis.

The mix of modalities performed by a particular practice will affect its overall result.

Why the result is less than the Conversion Factor Increase

The Proposed Rule contains adjustments to the valuation of certain services, as discussed more fully in our article “There Might Be Some Good News in the Medicare Physician Fee Schedule Proposed Rule for 2026”. Some arbitrary shifting of value away from the hospital setting and a blanket “Efficiency Adjustment” have changed many of the RVU values, offsetting the overall fee schedule increases that are proposed. The Proposed Rule also contains a site-of-service shift from facility-based (hospital) services to office-based services, however this adjustment will not apply to diagnostic radiology, according to the Radiology Business Management Association (RBMA) Federal Affairs Committee. The RBMA recently released its letter to CMS pointing out the flaws it perceives in the application of these two valuation adjustments.

Conclusion

Understanding the annual changes in Medicare’s fee schedules is useful when analyzing areas where the practice’s revenue might be increasing or decreasing. Many commercial payers base their fees on the Medicare table, although not all of them make the same changes, or at the same time, as Medicare does. Healthcare Administrative Partners will continue to keep you abreast of the Medicare payment system and subscribing to this blog is the best way to get the most current information available.

[i] The process used to perform a volume-weighted analysis involves gathering data from the previous year that shows the number of times each procedure code was billed for Medicare patients. The procedure volumes are multiplied by the 2025 Medicare fee schedule rates in one column, and again by the Proposed 2026 Medicare fee schedule rates in another column. Totaling each column will reveal the total practice revenue for the previous year and the reimbursement that the practice could expect in the current year assuming the volume of each procedure is unchanged.   The percentage increase or decrease can then be calculated.

Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.

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