CMS’s PFS Final Rule Impacts Medicare Rates for Pathologists

• CY 2026 Medicare PFS Final Rule increases pathologist reimbursement 0.5 percent for 2026 

The Centers for Medicare & Medicaid Services (CMS) published its CY 2026 Medicare Physician Fee Schedule on October 31. Despite ASCP, the American Medical Association, and other medical societies strongly opposing several controversial new proposals that will negatively impact pathologists and other specialists, CMS is adopting these proposals in its final rule.  Fortunately, Congress increased spending for the PFS by 2.5 percent during the summer, thus mitigating some of the impact of CMS’s new policies. 

These new policies include the efficiency adjustment and site of service differential payment rate and others.   

Efficiency Adjustment: CMS adopted its efficiency adjustment because it believes efficiencies are gained through practitioner experience, technological advances, and other operational improvements. ASCP pushed back on this proposal in its comments, citing several studies that found no such efficiencies. CMS also declined ASCP’s recommendation to exempt several pathology services (CPT codes 80503, 80504, 80505, and 80506) that ASCP argued were incorrectly included in CMS’s proposal. 

Site of service differential: CMS also finalized its site of service differential proposal, another proposal ASCP opposed. The new policy means that CMS will increase indirect costs for practitioners in office-based settings at the expense of providers working in facility settings.   

In addition, CMS has maintained the Merit-based Incentive Payment System (MIPS) performance threshold (to avoid a penalty) at 75 points for 2026, as requested by ASCP. CMS also adopted its proposed pathologist MIPS Value Pathway (MVP). Though the new MVP includes several elements that do not apply to pathology, ASCP is hopeful that CMS will consider changes that could make the MVP more applicable to pathologists.