The Medicare Physician Fee Schedule (MPFS) Final Rule for 2026 introduces several important updates that will directly affect physician reimbursement, operational planning, and compliance requirements. While much attention is often placed on the annual conversion factor, the 2026 Final Rule goes further—bringing changes to practice expense calculations, RVU methodology, dental coverage, social determinants of health reporting, telehealth policy, and supervision rules.
Physicians and medical practices must understand these updates early to protect revenue, remain compliant, and adapt workflows effectively.
1. Fees for 2026: Beyond the Conversion Factor
As expected, physician fees for 2026 are changing, and the impact goes well beyond adjustments to the conversion factor. While the conversion factor continues to influence overall payment rates, CMS has introduced additional structural changes that affect how services are valued.
Key Updates Include:
- Changes to practice expense (PE) logic, altering how direct and indirect costs are allocated
- Creation of differing RVUs for practice expenses, recognizing variations in resource use across settings
- Refined methodologies that may shift reimbursement between facility and non-facility services
What Physicians Should Do:
- Review specialty-specific fee schedule impacts, not just global changes
- Analyze how revised practice expense RVUs affect high-volume services
- Coordinate with billing and finance teams to forecast revenue changes for 2026
This is an area where expert medical compliance training can help practices correctly interpret payment logic and avoid misbilling under the revised RVU framework.
2. Expansion of Medicare Coverage for Dental Services
Dental services continue to evolve under Medicare, marking a significant shift from traditional coverage limitations. The 2026 MPFS Final Rule further defines this expanding area of reimbursement, particularly when dental services are integral to the treatment of covered medical conditions.
Key Clarifications:
- Medicare payment is allowed for certain dental services when they are:
- Medically necessary
- Inextricably linked to a covered medical procedure
- Coverage parameters are more clearly defined, reducing ambiguity for providers
What Physicians and Dental Providers Should Do:
- Ensure documentation clearly links dental services to covered medical care
- Educate billing teams on when dental services qualify for Medicare payment
- Monitor future CMS guidance as this coverage area continues to expand
This change presents both an opportunity and a compliance risk if services are billed without proper justification.
3. Social Determinants of Health (SDOH) Assessment Code Updates
The Social Determinants of Health (SDOH) Assessment code is undergoing notable changes in 2026, including a name change and updated policy guidance.
Why This Matters:
- CMS continues to emphasize the role of social and environmental factors in patient outcomes
- Accurate SDOH reporting supports care coordination, population health efforts, and value-based care initiatives
What’s Changing:
- Updated terminology and code description
- Clarified expectations for assessment and documentation
- Alignment with broader CMS equity and access goals
Action Steps:
- Train clinicians on appropriate use and documentation of SDOH assessments
- Update EHR templates to reflect the revised code name and guidance
- Avoid overuse or unsupported billing, which may trigger audits
Targeted expert medical compliance training is especially valuable here to ensure appropriate and defensible reporting.
4. Telehealth Services: Planning Beyond January 1, 2026
Telehealth reimbursement remains a critical concern for physicians. Under the MPFS Final Rule for 2026, payment for many telehealth services is extended only through January 1, 2026, reflecting a gradual return to pre-Public Health Emergency (PHE) policies.
Key Considerations:
- The extension is temporary, not permanent
- CMS continues to evaluate utilization, outcomes, and program integrity
- Practices should prepare for potential reductions in telehealth coverage after the extension expires
Practical Guidance for Physicians:
- Evaluate which telehealth services are essential vs. transitional
- Begin reintegrating in-person workflows where clinically appropriate
- Monitor CMS updates closely for permanent telehealth policy decisions
Proactive planning will help practices avoid sudden operational and revenue disruptions if telehealth policies tighten.
5. Virtual Supervision Is Now Permanent — With Important Limits
One of the most significant regulatory clarifications in the 2026 Final Rule is that virtual supervision has been made permanent. This allows supervising practitioners to meet supervision requirements via real-time audio/video technology.
Key Clarifications from CMS:
- Virtual supervision is permitted permanently
- It is intended for infrequent and limited use, not routine substitution
- The supervising practitioner must remain immediately available
What Practices Must Do:
- Clearly define when virtual supervision is appropriate
- Document supervisory availability and circumstances
- Avoid overuse, which could raise compliance concerns
CMS has been explicit that this flexibility is not meant to replace standard supervision models.
6. What Physicians Must Do Now: A Practical Action Plan
To successfully adapt to the Medicare Physician Fee Schedule Final Rule 2026, physicians should take immediate steps:
✔ Review Financial Impact
- Analyze conversion factor and RVU changes by specialty
- Update budgets and revenue projections
✔ Strengthen Compliance Infrastructure
- Update billing policies and internal guidelines
- Invest in expert medical compliance training for providers and staff
✔ Update Documentation and Coding Practices
- Align dental, SDOH, and telehealth documentation with CMS guidance
- Ensure virtual supervision is properly recorded
✔ Prepare for Policy Transitions
- Develop a post-telehealth-extension strategy
- Monitor CMS updates throughout 2026
Conclusion
The MPFS Final Rule for 2026 reflects CMS’s continued shift toward refined payment accuracy, expanded access, and increased accountability. While these changes create new opportunities, they also introduce complex compliance challenges.
Physicians who act early—by understanding payment changes, strengthening documentation, and investing in expert medical compliance training—will be best positioned to protect revenue, reduce risk, and deliver high-quality care in 2026 and beyond.