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July 21, 2025

We want to make sure you know we have your back. We’re actively responding, relentlessly pushing forward, and ensuring your voice is heard loud and clear on Capitol Hill. Please keep reading Capitol Hill Report—and tell your colleagues—for a rundown of how your AAN is in overdrive advocating on your behalf. We’re analyzing and monitoring all changes made by Congress and the administration to evaluate any impacts on neurology and the patients we serve. If your practice, research, or patients have been impacted by recent changes at the federal or state level, please let us know by emailing advocacy@aan.com.

Issue in focus

Each year, the Centers for Medicare & Medicaid Services (CMS) proposes regulations that impact the reimbursement of physicians. On July 14, 2025, CMS issued a proposed rule updating payment policies and rates for physicians paid under the Medicare Physician Fee Schedule (PFS) in 2026. The proposed rule illustrates the importance of the AAN’s regulatory advocacy efforts on behalf of neurologists and their patients.   

CMS is projecting that the overall impact of changes contained in the proposed rule will result in a projected 1% increase in payments to neurology as a specialty, broadly. Additionally, CMS is proposing to increase the Medicare conversion factor. This news is driven in part by the AAN’s advocacy efforts on Capitol Hill, which resulted in Congress passing a 2.5% increase to the conversion factor for 2026. Due to additional statutory requirements from the Medicare Access and CHIP Reauthorization Act of 2015, the recently passed increase, and the changes in the PFS, Medicare reimbursements are projected to increase 3.84% for qualifying alternative payment model (APM) participants and 3.32% for non-qualifying clinicians.   

Following efforts to ensure uninterrupted access to telehealth services by the AAN and other stakeholders, CMS is proposing to remove the “provisional” and “permanent” categories of services listed in the Medicare Telehealth Services List and consider all telemedicine services permanent if the service meets certain statutory requirements. Additionally, CMS is proposing to remove frequency limitations of certain inpatient and nursing facility visits and critical care consultation services, and permanently adopt a definition of direct supervision that allows the physician or supervising practitioner to provide such supervision through real-time audio and visual interactive telecommunications (excluding audio-only). AAN advocacy remains heavily engaged with Congress on telemedicine, as many telehealth flexibilities established during the COVID-19 Public Health Emergency are set to expire in September of this year. &²Ô²ú²õ±è;

CMS is proposing several policy changes aimed at improving payment accuracy. First, the agency is proposing to expand the use of the G2211 complexity add-on code to include home or residence E/M visits. For non-time-based services, CMS is proposing an efficiency adjustment, including for codes reviewed by itself or the AMA RVS Update Committee. The efficiency adjustment will cause a 2.5% negative adjustment in 2026 for certain codes, with calculations reoccurring every three years. Regarding global surgical packages, CMS is considering potential strategies to achieve more accurate valuation and payment to the provider performing a portion of the global surgical service, given long-standing concerns regarding the valuations of these packages.

Regarding drug reimbursements, CMS is proposing additional guidance to ensure that the average sales price (ASP), which determines the payment limit for drugs paid under Medicare Part B, considers factors accurately. The agency is also proposing to exclude drugs that a manufacturer provides at a discount under the 340B Program from the Prescription Drug Inflation Rebate Program. &²Ô²ú²õ±è;

For the Quality Payment Program, CMS is proposing to maintain weights for the Merit-based Incentive Payment System (MIPS) performance categories at their current weight for 2026 and is proposing limited changes to the program. It’s also proposing an expanded portfolio of MIPS Value Pathways (MVPs) and is revising the format of each MVP to categorize the quality measures by clinical conditions or episodes of care. &²Ô²ú²õ±è;

CMS is also proposing a new Ambulatory Specialty Model (ASM). The model aims to improve prevention, enhance quality of care, and reduce low-value care by improving upstream management of chronic disease. Participation in the ASM will be mandatory for specialists who commonly treat people with heart failure or low back pain. &²Ô²ú²õ±è;

Finally, CMS has issued a request for information (RFI) seeking stakeholder input on payment policies and the use of software that may enhance prevention and management of chronic disease. &²Ô²ú²õ±è;

We’re dedicated to representing you and your patients. Our advocates will keep engaging with CMS throughout the comment period, providing feedback on how the relevant policies and standards impact quality neurological care. &²Ô²ú²õ±è;

Read the AAN’s summary. &²Ô²ú²õ±è;

 
Latest advocacy news

AAN urges Congress to honor its investment in overcoming Alzheimer’s disease 
As part of the LEAD Coalition, the AAN joined over 480 organizations this month in sending a letter to the House and Senate Appropriations Committee urging Congress to continue to honor its investment in approaches to overcoming Alzheimer's disease and related disorders. The letter asks the committee to create robust appropriations for federal agencies to participate in the National Alzheimer's Project Act (NAPA) advisory council to meet its goals, guarantee the work of NAPA stakeholders goes uninterrupted, and ensure full and timely expenditure of those funds for their intended purposes. &²Ô²ú²õ±è;

Recent comment letters 
The AAN has recently provided policymakers with written comments on topics such as the National Alzheimer’s Project Act and Prior Authorization reform. Sending comment letters on key priorities or signing onto letters with other organizations is an important component of the AAN’s advocacy efforts. Read our other comment letters. 

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