On July 14, the Centers for Medicare & Medicaid Services filed the 2026 Medicare Physician Fee Schedule and Quality Payment Program proposed rule, which includes potential revisions to payment policies under the physician fee schedule, quality payment program and other Medicare Part B payment policies.

The AASM Quality & Health Policy team conducted an analysis of the proposed rule, and the AASM responded to several proposals that, if finalized, would potentially impact sleep medicine care and reimbursement. The AASM submitted a comment letter in response to the rule, advocating on behalf of individual and facility members. Several key highlights are included below.

The AASM responded to the following CMS proposals:

  • 2026 Physician Fee Schedule rate-setting and conversion factors, which fail to account for rising costs of providing high-quality patient care
  • Proposed downward efficiency adjustment of 2.5%, which would reduce work relative value units and intraservice physician time for non-time-based services, based on the implication that physicians will automatically become more efficient in delivering care over a specific time period
  • Concerns regarding the validity and reliability of the physician practice information survey data
  • Updates to the practice expense methodology, which would reduce indirect practice expense relative value units for facility-based services
  • The Relative Value Scale Update Committee’s progress in identifying and reviewing potentially misvalued codes
  • Nomination of electronic analysis of implanted neurostimulator pulse generator/transmitter codes (95970, 95976 and 95977)
  • Nomination of 95800 as a potentially misvalued code
  • The methodology for developing direct practice expense inputs
  • Telehealth flexibilities
  • Ability to report G2211 for home and residence-based evaluation and management visits
  • Determination of professional liability relative value units
  • The impact of geographic practice cost indices
  • Chronic disease prevention and social drivers of health
  • Updates to the Quality Payment Program
  • Requests for information:
    • Administrative burden
    • Core elements in a MIPS value pathway
    • Well-being and nutrition measures
    • Data quality

Review the AASM response to the proposed rule here.

As CMS reviews all comments and prepares for publication of the 2026 final rule, AASM will continue to advocate for members to receive appropriate reimbursement for the delivery of high-quality care to patients with sleep disorders. Members may send questions about the proposed rule to coding@aasm.org.