On Monday, July 14, the Centers for Medicare & Medicaid Services (CMS) released the CY 2026 Medicare Physician Fee Schedule proposed rule and fact sheet. The following is a high-level summary of the policies that will affect AUA members. AUA staff will be reviewing the proposed rule and submitting comments in advance of the September 12 deadline.

• CY 2026 MPFS Impacts on Urology Codes Compared with CY 2025 Rates (Facility and Non-Facility Rates)
• CY 2026 MPFS Impacts on Evaluation & Management Codes Compared with CY 2025 Rates (Facility and Non-Facility Rates)

Conversion Factor

2026 marks the first year that there are two separate conversion factors: one for practitioners working in a qualifying advanced APM and the other for those not in a qualifying APM. The conversion factor for the former will increase to $33.59, an increase of 3.83%, and the latter to $33.42, an increase of 3.62%. These increases reflect the 2.5% increase to the conversion factor included in the reconciliation package recently adopted by Congress.

Impact to the Specialty of Urology

CMS estimates that, if implemented, the policies in the rule will have a net impact of 0% in total Medicare charges for urology. However, CMS proposes to change the methodology for the allocation of indirect practice expenses (PE) within the physician payment formula which will decrease overall charges for urology in the facility setting by -11% but increase payments by +6% in the non-facility (office) setting. According to the agency, this proposed change will reflect the current state of clinical practice with fewer physicians working in private practice settings, and therefore, “the allocation of indirect costs for PE RVUs in the facility setting at the same rate as the non-facility setting may no longer reflect contemporary clinical practice.” CMS is choosing to do this adjustment to the indirect PE because the agency has decided not to use the AMA Physician Practice Information Survey (PPIS) survey data, even after the agency delayed making changes to the indirect PE allocations as it waited on the new survey data. The AUA contributed to the AMA PPIS data collection effort and is disappointed the agency chose not to incorporate it into its update to the indirect PE allocations.

Note that impact of proposed policies on group practices and individual physicians varies based on practice type, payer type, mix of patients and the types of services provided to those patients.

CMS Accepts Nearly All RUC Recommendations for Urology Services

The AUA continues to serve our members by participating in the AMA RUC process and advocating for relative value units (RVUs) that reflect the work of urologists. By participating in the RUC survey process, the Society advocates for work and practice expense values for new and revised CPT codes. In this rule, CMS proposes to accept the AMA RUC recommended values for all the services recently surveyed by the AUA except for two codes. The AUA surveyed services for laparoscopic prostatectomy, transurethral robotic-assisted resection of the prostate, prostate biopsy services, cystourethroscopy, and temporary female intraurethral valve-pump services. Of note, the new CPT codes and RVUs established for prostate biopsy services will be used in 2026, but the AUA is revising the code set and hopes the revisions will be ready for implementation in 2027.

Appendix A lists new and resurveyed codes with RUC recommended values and CMS proposed values for services performed by urologists.

Efficiency Adjustment Proposed to Address Perceived Overvalued Services

CMS has taken aim at the RUC process with a proposal to decrease work RVUs and corresponding intraservice time by 2.5% for nearly every service on the fee schedule except time-based codes, including evaluation and management services, care management services, behavioral health services, services on the Medicare telehealth list, and maternity codes with a global period of MMM. The efficiency adjustment is meant to account for efficiency gains over time as practitioners become more skilled at performing procedures, and hence performing those procedures faster than the intraservice times listed in the RUC time files. The agency continues to believe that RUC survey process is flawed due to low response rates and perceived conflicts of interest of those who take RUC surveys. CMS states “research over time has demonstrated that the time assumptions built into the valuation of many PFS services are, as a result, very likely overinflated.”

Additionally, CMS notes in the rule that they are seeking comments on alternative data sources to use in the valuation process and would give preference to empiric data that supports the valuation of services on the Medicare PFS. The agency signals that “moving away from survey data would lead to more accurate valuation of services over time and help address some of the distortions that have occurred in the PFS historically.”

Agency Again Seeks Comments on the Valuation of the Global Surgical Package

The recent OIG report on the global surgical package coupled with the administration’s efforts to reduce fraud, waste, and abuse, puts the global surgical payment concept once again back in the spotlight. The agency continues to support its stance that not all post-operative visits included in the valuation of surgical procedure are provided to patients during the global period, and therefore procedures are overvalued. The proposed rule states that a study of 90-day globals during 2023 dates of service that only 28% of post-operative visits valued into the global surgical package were provided to Medicare beneficiaries.

The agency did not propose any changes to policy implemented last year to assist with data collection on the global surgical package values and will continue to collect data using modifier -54 (surgical care only) and G0559 (postoperative care services furnished by a practitioner other than the one who performed the surgical procedure (or another practitioner in the same group practice).

To help determine the best way to value the global surgical package, CMS seeks comments on the shares of work between surgeons and the providers of post-operative care. Additionally, CMS seeks comments on the use of CPT code 99024 (a non-payable code) to capture data about the number of post-operative visits provided and by whom.

Telehealth Updates

CMS continues to support the use of telehealth. The agency proposes to simplify the review process for adding services to the Medicare Telehealth Services List, and to remove the distinction between provisional and permanent services.

CMS proposes to permanently adopt a definition of direct supervision for certain services that allows the physician or supervising practitioner to provide supervision through real-time audio and visual interactive telecommunications. Finally, the agency proposes to not continue the policy that allows teaching physicians to have a virtual presence for services provided by residents in teaching settings and would revert to requiring that teaching physicians maintain a physical presence during critical portions of resident-furnished services to qualify for Medicare payment.

Appendix A: RUC Recommended and CMS Proposed Work RVUs

Green highlighted codes are new services. Final code numbers will be released in the 2026 final rule.