- within Real Estate and Construction, Insolvency/Bankruptcy/Re-Structuring and Consumer Protection topic(s)
Guest Article
CMS releases 2026 medicare fee schedule final rule, nephrology slated for +1% payment increase
Author: Robert Blaser, Director of Public Policy, Renal Physicians Association
The final rule for the 2026 Medicare Fee Schedule was released by the Centers for Medicare and Medicaid Services (CMS) on October 31, and it appears to have been finalized almost exactly as it was proposed. As a result, nephrology is still slated to have a projected impact of +1%, and the inpatient/outpatient dichotomy is as it was in July, as the methodological changes for the work relative value units (RVUs, adjusted via what CMS is calling the efficiency adjustment—EA—which implements a 2.5% reduction for affected services) and the practice expense RVUs (via changes to the indirect PEs) are still in place. Thus, the approximate -9.4% hit for (for example) CPT code 90935 (typically inpatient dialysis) and the approximate +9.0 increase for 90960 (adult outpatient monthly dialysis) are finalized as proposed. Accordingly, all of the changes to the dialysis code family and to E&M codes are as proposed in July, with healthy increases for outpatient dialysis and E&M services, and corresponding cuts to inpatient dialysis and E&M codes. As such, nephrology practices that provide a higher percentage of inpatient services will be negatively impacted, while practices providing predominantly outpatient services will see payment increases. One change made to the efficiency adjustment proposal is to exempt new codes from the adjustment, a change for which RPA and other group advocated.
Regarding the conversion factor (CF) , this too in unchanged from what was proposed, so, quoting the CMS press release on the rule, "the final CY 2026 qualifying alternative payment model (APM) conversion factor of $33.57 represents a projected increase of $1.22 (+3.77%) from the current conversion factor of $32.35. Similarly, the final CY 2026 nonqualifying APM conversion factor of $33.40 represents a projected increase of $1.05 (+3.26%) from the current conversion factor of $32.35." Recall that this is the first year of the two-conversion factor system mandated by The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) that gives a higher bonus for qualifying APM participants and a lower increase for non-qualifying Medicare Part B providers.
On another issue relevant to nephrology, CMS declined to add what are typically inpatient dialysis codes (CPT codes 90935, -37, -45, and -47) to the approved Medicare telehealth list. In describing the comments CMS received on this issue, the rule states that: The commenters provided information that these codes are generally used to treat critically ill, potentially hospitalized patients who are best treated in-person rather than via telehealth. These commenters acknowledged that there may be extremely limited circumstances in which patients in rural areas may benefit from these services being on the Medicare Telehealth Services List, but that in most cases, these patients would require an in-person visit.
This aligns with comments provided by RPA and other groups on the rule. RPA's comments stated that the organization "supports the use of telehealth and other evolving technologies for many Medicare-covered services and believes in its potential to expand access to care for all kidney patients. However, CPT codes 90935, -37, -45, and -47 all typically describe services provided to hospitalized patients who are acutely ill and, in most cases, require a face-to-face visit. RPA does recognize that there would be value in the 90935-47 code set being available for care provided by telehealth in rural settings, and if there were an exclusion process that would limit its use to care provided in rural settings, that would be reasonable and appropriate. Otherwise, we do not believe that CPT codes 90935, -37, -45, and -47 should be added to the Medicare Telehealth Services List."
In summary, with a few exceptions the rule was finalized as proposed. That said, it is RPA's understanding that some surgical/procedural specialty societies will be strenuously lobbying Congress to eliminate the 2.5% EA reduction. This probably has uncertain prospects at best, given the government shutdown and the inherent difficulty in advancing legislative initiatives of this nature. RPA will track any developments pertaining to the 2026 Medicare Fee Schedule and will keep the kidney community advised as appropriate.
Nephrology and Dialysis
SEPTEMBER 30, 2025
Ultraprocessed foods linked to higher hyperphosphatemia risk in Brazilian hemodialysis patients
A secondary analysis of a cross-sectional study in seven Brazilian dialysis units examined the impact of dietary diversity on hyperphosphatemia in long-term hemodialysis patients.
The study assessed 297 patients (mean age 52) using validated questionnaires to measure consumption of unprocessed or minimally processed foods versus ultraprocessed foods (UPFs).
While UPFs were consumed less frequently than unprocessed foods, higher intake, particularly from animal-based UPFs, was independently associated with increased risk of hyperphosphatemia.
Each one-point rise in UPF consumption raised the likelihood of hyperphosphatemia by 25% for total UPFs, 76% for animal-based UPFs, and 24% for other UPFs.
Source: DocWire News
To view the full article please click here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
