Medicare Physician Fee Schedule Proposed Rule

IPSIS submitted comments 🔒 to the Centers for Medicare and Medicaid Services (CMS) in response to the 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule. Comments focused on four main areas:

• Conversion Factor
  IPSIS urges CMS to advocate for Congressional action to permanently align physician payment updates with the Medicare Economic Index (MEI). While CMS announced modest increases to the conversion factors, IPSIS emphasizes that these changes are insufficient to keep pace with rising practice costs.
  
  
• Efficiency Adjustment to Work RVUs and Intra-Service Time
  CMS proposed a 2.5% across-the-board reduction in work RVUs and intra-service time. IPSIS strongly opposes this blanket cut, noting that it is based on unfounded assumptions of efficiency gains and fails to reflect the complexity of interventional pain procedures. IPSIS warns that such cuts would destabilize physician payment, discourage innovation, and ultimately restrict patient access to safe, evidence-based pain management.
  
  
• Indirect Practice Expense in the Facility Setting
  CMS proposed reducing the work RVU input in the facility practice expense formula, which could lower payments in the facility setting by 7% while slightly increasing non-facility payments. IPSIS cautions that this approach underestimates the real resource costs of facility-based interventional pain care and could reduce access by making it more difficult for independent physicians to sustain practice in these environments.
  
  
• Ambulatory Specialty Model (ASM) for Low Back Pain Episodes
  CMS proposed launching a mandatory alternative payment model beginning in 2027. While supportive of efforts to improve care coordination, IPSIS raises concerns about the model’s design, including the low minimum case threshold of 20, heavy weighting on cost measures, and application of payment adjustments to all of a clinician’s Medicare services. IPSIS recommends a voluntary or phased approach, higher case minimums, and clear, transparent performance standards to avoid undermining patient access to minimally invasive treatments.

Click here 🔒 to read the comment letter. 

Monitoring and commenting on CMS rule-making to advance evidence-based policies that expand access to safe, effective treatments for individuals suffering from debilitating pain is a significant function of IPSIS. Help sustain this vital advocacy with your donations. The International Pain and Spine Intervention Society (IPSIS) is a tax exempt organization under US section 501(c)(3) of the Internal Revenue Code. As such, contributions are deductible to the extent allowed by law.