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August 1, 2025

The Centers for Medicare & Medicaid Services (CMS) published its annual proposed rule in mid-July, laying out a set of regulations updating payment policies and rates for clinicians paid under the Medicare Physician Fee Schedule in 2026. A 60-day comment period is underway, and the agency will issue its final rule in November. The AAN will submit extensive formal comments in advance of the comment deadline to inform agency decision-making on the final rule.

AAN member advocates and staff continue to analyze the proposed rule for its impacts on neurology, and we’ll keep engaging with CMS throughout the comment period to provide feedback on how our members and their patients will be affected. 

In the meantime, what should AAN members know about the proposed rule? Here’s a quick primer.

How will this affect physician payment?

Physicians overall would see a conversion factor increase of 3.3% or 3.8%, with the higher percentage applied to qualifying alternative payment model participants. This increase is largely due to Congress’s passage of a 2.5% increase to the 2026 conversion factor, an addition to July’s reconciliation bill that shows the impact of AAN member advocacy, and statutorily required increases of 0.75% for qualifying APM clinicians and 0.25% for all other clinicians. CMS projects that changes in the proposed rule, in addition to those legislative changes, will result in a 1% increase in payments to neurology as a specialty.

While the AAN supports a comprehensive solution to longstanding issues with the physician payment system—such as an annual adjustment tied to the Medicare Economic Index to ensure physicians’ compensation keeps pace with inflation—the AAN is encouraged by this increase for 2026. We will keep working with legislators to advocate for broader long-term payment reform to ensure your work is adequately valued.

Are there updates for telehealth?

Uninterrupted access to telehealth is crucial for many people with neurological disease, especially those who live in rural or underserved areas. Access to these services was expanded during the COVID-19 pandemic, remaking the health care landscape and significantly lowering barriers to care. While Congress has granted short-term extensions—the most recent of which is set to expire on September 30, 2025—it has yet to act to make telehealth expansion permanent.

However, following telehealth advocacy 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 focus on whether the service can generally be furnished using an interactive, two-way audiovisual communication technology. This means that instead of separately adjudicating services for which it receives requests for permanent status, all services that meet statutory requirements would be considered included on a permanent basis, and the agency would allow providers to exercise their professional judgment. 

The agency is also 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 of auxiliary personnel via video call. 

As the deadline for Congress to protect telehealth access draws near, the AAN remains heavily engaged in advocacy on this topic to ensure that critical flexibilities remain in place for the long term.

What should I know about the efficiency adjustment?

In recent years, CMS has requested comments on the process for valuing physicians’ work, including how it evaluates E/M services. The AAN and other stakeholders have noted the resources used in these services are primarily a function of the time the clinician spends with the patient, and not amenable to efficiency gains. This has led to concerns related to the passive devaluation of E/M services. 

For 2026, CMS is proposing to implement an efficiency adjustment to the work RVU and corresponding intraservice portion of non-time-based services that are expected to accrue gains in efficiency over time. This would periodically apply to all codes except time-based codes, such as E/M services, care management services, behavioral health services, services on the Medicare telehealth list, and certain maternity care codes. 

The agency is proposing to apply a negative efficiency adjustment of 2.5% for CY 2026, including codes that CMS or the AMA RUC have reviewed within a look-back period of 5 years. Going forward, the efficiency adjustment would be every three years with the next calculated and applied in CY 2029 rulemaking.

What about practice expense?

CMS is also proposing changes to the formula used to calculate practice expense in facility settings. Implementation of this proposal would redistribute funds towards non-facility practice and reduce reimbursement for practice expense in facility settings.

Where can I learn more? 

For a longer list of changes in the proposed rule that the AAN is watching, read our summary. It provides a more detailed look at these topics and several others.

How can I get involved in neurology advocacy? 

The easiest way to stay informed on both advocacy updates and chances to get involved is to read our Capitol Hill Report newsletter, which is emailed to US members and posted online every two weeks. This is where you can learn about new action alerts, opportunities to apply for in-person events like Neurology on the Hill, and summaries of key legislative and regulatory happenings. 

It’s also a good idea to sign up for the , where you can receive exclusive updates on the AAN's federal, regulatory, and state advocacy efforts and join us for quarterly advocacy webinars on the most pressing issues facing neurology. 

See other ways to get involved.