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Medicare 2026 Payment Updates

5 Nov 2025 12:08 PM | Zachary Edgar (Administrator)

Overall potential 4% cut without changes by January 30, 2026.

The 2026 MPFS includes modest payment updates but continues to place downward pressure on speech-language pathology reimbursement. Although Congress approved a one-time 2.5% payment increase for 2026, these gains may be offset by new Centers for Medicare & Medicaid Services (CMS) policies and mandatory federal budget reductions, resulting in potential overall cuts of approximately 4% without additional legislative intervention.

Congress establishes annual payment updates to the MPFS, which were frozen at 0.0% from 2020 through 2025 because of a provision in the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015.

Beginning in 2026, MACRA put in place a variable annual update dependent on participation in Advanced Alternative Payment Models (APMs). Those clinicians participating in APMs will receive an annual update of 0.75%. All other clinicians are eligible for a 0.25% annual update. The One Big Beautiful Bill Act (OBBBA) also provided a one-time positive payment update of 2.5% for 2026. Additional payment adjustments—based on legislative and regulatory actions, or participation in the MIPS or APMs—may also apply.  

Significant payment cuts to all services provided under the MPFS will continue in 2026. These cuts have gone into effect each year since 2021 due to changes in payment for outpatient office-based evaluation and management (E/M) services and adjustments to the annual conversion factor.

Conversion Factor (CF)

CMS uses the CF to calculate MPFS payment rates. Beginning 2026, there will be two separate CFs: 1. $33.57 for clinicians who participate in a qualified APM, representing a 3.8% increase from the 2025 CF. 2. $33.40 for clinicians who do not participate in a qualified APM, representing a 3.3% increase from the 2025 CF.

Most therapists do not participate in a qualifying APM and will use the $33.40 CF to calculate payment rates. These CFs reflect the combined increases mandated in MACRA and OBBBA (explained in more detail above) but fail to account for reductions that will be applied due to a variety of policy changes such as the efficiency adjustment imposed by CMS and elimination of the geographic practice cost index (GPCI) floor, which will reduce payment to specific localities beginning January 31, 2026. In some instances, these reductions eliminate and further reduce the legislative increases provided by Congress.

Efficiency Adjustment

For 2026, the efficiency adjustment will be -2.5 percent.

Full list of codes subject to the efficiency adjustment 

Malpractice (MP) RVUs and Geographic Practice Cost Indices (GPCIs)

CMS updates both MP RVUs and GPCIs every three years to ensure that payments remain aligned with current cost and risk data. The next update will take effect in CY 2026 and will impact payment rates for therapy services.

MP RVUs represent the portion of a CPT code’s total RVU that accounts for professional liability insurance costs associated with a service. These values are based on the relative risk of malpractice claims across different medical specialties. While most MP values for speech-language pathology services did not change, CMS has finalized additional reductions to MP values for certain codes and did not provide significant increases to MP values. GPCIs adjust Medicare payments to reflect differences in the cost of care across various regions of the country.

There are three separate GPCIs corresponding to the three RVU components:

  •         Work GPCI, which adjusts for geographic differences in clinical labor costs;
  •         Practice Expense GPCI, which accounts for regional variation in overhead costs such as rent, staff wages, and supplies; and
  •         Malpractice GPCI, which reflects differences in malpractice insurance premiums among geographic areas.

A nationwide 1.0 floor for the work GPCI was temporarily extended through January 30, 2026. Congress will need to once again extend the floor or make it permanent. Otherwise, geographic localities previously benefiting from it may see reductions in work GPCI-related payments in CY 2026.

Multiple Procedure Payment Reductions (MPPR)

The MPPR policy for therapy services will continue in 2026. Under this system, per-code payment is decreased when multiple therapy services are performed for a single beneficiary on the same day. This per-day policy applies to services provided by all therapy disciplines (i.e., speech-language pathology, physical therapy, and occupational therapy) in the same facility.

Therapy Threshold

The therapy threshold increases by 1.7 percent.

$2,480 for physical therapy and speech-language pathology services combined, and $2,480 for occupational therapy services. The threshold for targeted medical review remains $3,000 for combined physical therapy and speech-language pathology services, and $3,000 for occupational therapy services.

Telehealth

In addition, the CMS finalized permanent telehealth coverage for speech-language pathology codes— though congressional action has only extended coverage for therapists through January 30, 2026.

Remote Therapeutic Monitoring

Four new remote therapeutic monitoring (RTM) codes have been added for 2026, although one code, 98986, is specifically designated for cognitive behavioral therapy.

  • 98984: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 2-15 days in a 30-day period
  • 98985:Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 2-15 days in a 30-day period
  • 98986: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 2-15 days in a 30-day period
  • 98979: Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least 1 real-time interactive communication with the patient or caregiver during the calendar month; first 10 minutes

Also finalized were the updated descriptors for three additional RTM codes: 

  • 98976: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 16-30 days in a 30-day period
  • 98977: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 16-30 days in a 30-day period
  • 98978: Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 16-30 days in a 30-day period


About Me

Zachary Edgar JD, LLM is Therapy Comply's managing partner.  Zachary is a healthcare attorney who specializes in federal and state healthcare regulatory issues particularly for physical, occupational, and speech therapy practices.  

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