ASCRS News: Government Relations Update
Fall 2025
by Susanne Hewitt, MD
ASCRS Government Relations Committee Chair
ASCRS Government Relations continues to fight for the best interests of ASCRS members in regard to Medicare reimbursement and other key legislative and regulatory issues.
ASCRS attends Legislative Fly-In
Representatives from ASCRS met in Washington, D.C., in July to participate in the Alliance of Specialty Medicine Legislative Fly-In. The Fly-In is organized by the Alliance to bring the 16 member medical specialty societies to Washington, D.C., to learn about policy issues affecting the specialty medical community and to meet directly with their representatives and senators to lobby for policy initiatives.
This was the 25th year ASCRS participated in the Fly-In. ASCRS members met with legislators to discuss ongoing problems with the Medicare Physician Fee Schedule, the need for prior authorization reforms, and to lobby for an increase in the number of residency slots across the country.
Reimbursement updates
Also in July, the 2026 Medicare Physician Fee Schedule (MPFS) Proposed Rule and the 2026 ASC Proposed Rule were released. The ASCRS Government Relations team reviewed these proposed rules and submitted comments regarding the proposals prior to the September 12 deadline. Notably, the proposed Medicare payment rate for a standard cataract procedure, 66984, is estimated to be $466.87, which is an 11% decrease from the 2025 Medicare payment of $521.75. The significant decrease is due to changes to two proposals: the newly proposed efficiency adjustment that will impact work RVUs and changes to the methodology in calculating the indirect practice expense.
In the rule, CMS argues that physicians providing non-time based services, particularly procedures, radiological services, and diagnostic testing, will become more efficient as they gain more experience and technology continues to advance. Therefore, CMS is proposing to apply an efficiency adjustment to work RVUs. For CY26, the proposed efficiency adjustment is –2.5%.
ASCRS Government Relations continues to fight for the best interests of ASCRS members in regard to Medicare reimbursement and other key legislative and regulatory issues.
Additionally, CMS thinks the decline in the number of physician-owned practices means providers no longer need to maintain office-related expenses and that the current indirect PE allocations are overstated. The equation to calculate indirect expenses is highly technical. As part of the overall equation, CMS uses work RVUs. CMS has proposed to reduce the portion of facility PE RVUs allocated based on work RVUs to half the amount allocated to non-facility PE RVUs. CMS’s proposal will reduce the PE RVUs for facilities.
ASCRS disagrees with CMS’ assumptions related to the efficiency adjustment and changes in the practice expense methodology. ASCRS continues to work with the AMA and other medical specialties in advocating for policies that accurately reimburse physicians for the services they provide and ensure patient access to these services.
Under the 2026 MPFS Proposed Rule, the proposed 2026 conversion factor was $33.59 for qualifying Alternative Payment Model (APM) participants and $33.42 for nonqualifying APM participants.
As required by MACRA statute, there are two conversion factors for CY26, a conversion factor update of +0.75% for qualifying alternative payment model (APM) participants (QP) and a conversion factor update of +0.25% for nonqualifying APM participants (or those participating in traditional MIPS). Additionally, the One Big Beautiful Bill Act of 2025 includes a 2.5% update for CY26. Therefore, the conversion factor for QPs is $33.59, while the conversion factor for nonqualifying QPs is $33.42.
The CY 2026 proposed MPFS conversion factors of $33.59 and $33.42 represent a 3.83% and 3.62% increase from the CY 2025 MPFS conversion factor (CF) of $32.3465.
CY 2026 proposed MPFS conversion factor reflects the following:
- Mandated updates of 0.75% for APM QPs and 0.25% for nonqualifying participants
- Mandated 2.5% update for CY26 enacted in the One Big Beautiful Bill Act of 2025
- Estimated +0.55% adjustment necessary to account for proposed changes in work RVUs for some services
Under the 2026 ASC Proposed Rule, CMS proposed to adjust the CY 2025 ASC conversion factor ($54.895) by the proposed wage index budget neutrality factor of 0.9999 in addition to the proposed productivity-adjusted hospital market basket update of 2.4%, which resulted in a proposed CY 2026 ASC conversion factor of $56.207 for ASCs meeting the quality reporting requirements.
For ASCs not meeting the quality reporting requirements, CMS proposed to adjust the CY 2025 ASC conversion factor ($53.828) by the proposed wage index budget neutrality factor of 0.9999 in addition to the quality reporting/productivity-adjusted hospital market basket update of 0.4%, which results in a proposed CY 2026 ASC conversion factor of $55.109 for ASCs not meeting the quality reporting requirements.
CMS also proposed extending the utilization of the hospital market basket update as the update factor for the ASC payment system for one additional year, through CY 2026, while CMS continues to study the migration of outpatient surgical procedures.
The proposed ASC payment rate for cataract surgery, CPT 66984, was estimated to decrease by 5% of the CY25 payment rate of $1,371. Overall, CMS proposed a 2% decrease in eye surgical procedure payments. The decrease is due to relative decline in the OPPS relative weights for the Level 1 Intraocular Procedures APC, which is attributable to the relative decline in hospital geometric mean costs for procedures assigned to this APC.
Contact
Hewitt: suehewitt111@gmail.com
