The Centers for Medicare & Medicaid Services (CMS) has released the CY 2026 Medicare Physician Fee Schedule (MPFS) proposed rule. If finalized, these changes will take effect January 1, 2026, and they bring important implications for physical therapy billing and reimbursement.
At Park Medical Billing, we provide rehab therapy billing services and outsourced RCM solutions that help practices stay compliant and financially healthy. Here’s what PT clinics need to know.
Payment Updates: Dual Conversion Factors
For the first time, CMS proposes two conversion factors (CFs):
- APM-Qualified Providers: $33.59 (+3.83%)
- Non-APM Providers (most PTs): $33.42 (+3.32%)
Impact: Even with CF increases, CMS projects small net decreases in PT reimbursement due to RVU adjustments. Some CPT codes may increase in value, while others decline.
RVU Efficiency Adjustments
CMS proposes a –2.5% efficiency adjustment on the intraservice portion of non-time-based codes. For PTs, this could mean reduced payments on certain services despite the conversion factor bump.
As your medical billing partner, Park Medical Billing can provide a CPT impact analysis to help identify where your revenue may be at risk.
Easier Remote Therapeutic Monitoring (RTM)
CMS proposes expanding RTM opportunities:
- Billable with 2–15 device days (instead of 16+) per 30-day period
- Management time reduced to 10 minutes/month (from 20)
Opportunity: RTM offers PTs a new revenue stream while improving patient engagement. Our RCM services ensure these claims are submitted clean and paid quickly.
Practice Expense (PE) Methodology
Proposed PE changes may shift reimbursements:
- Office-based PTs could benefit from better overhead allocations
- Facility-based PTs may see cuts in indirect PE RVUs
Documentation & Telehealth
- KX Modifier: Stronger emphasis on medical necessity documentation. Practices should refine workflows to reduce denial risk.
- Telehealth: CMS proposes to streamline the Telehealth Services List and extend some flexibilities. Permanent coverage for therapy telehealth remains uncertain until the final rule.
Action Steps for PT Practices
- Review top CPT codes for potential reimbursement impact
- Add RTM services to diversify revenue
- Strengthen documentation workflows for KX compliance
- Optimize for non-facility payment advantages
- Stay tuned for the final rule in November 2025
Final Thoughts
The CY 2026 CMS MPFS proposed rule creates both risks and opportunities for physical therapists. By acting early, PTs can adapt to payment shifts, capture new RTM revenue, and keep billing compliant.
At Park Medical Billing, our team provides:
- Specialized rehab therapy billing services for PT, OT, and SLP clinics
- Outsourced RCM services to minimize denials and improve collections
- CPT impact analysis to prepare your practice for 2026
- Reporting and analytics to keep your finances transparent
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