While physicians are expected to see increased payments in six years, proposed "efficiency" adjustments threaten to cut payments for other essential services. The health equity impact of these adjustments is not known. Furthermore, several key changes risk undoing years of effort to integrate health equity into quality programs. These include removing health equity initiatives from quality improvement activities, eliminating the Screening for Social Drivers of Health measure, and ending health equity adjustment scoring. The unraveling of these efforts, along with the removal of requirements to screen patients for social health needs and the elimination of incentives for organizations serving medically underserved communities, represents a significant setback to health equity initiatives.
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A legally binding directive issued by a federal agency to implement, interpret, or enforce laws passed by Congress. Rules go through a formal rulemaking process, including public notice and comment, before taking effect.
Who It Impacts: Businesses, organizations, and individuals subject to federal agency oversight. For example, a new environmental regulation could impact manufacturing companies, or a healthcare rule could affect providers and insurers.
Who Is Not Impacted: People or entities not subject to the agency’s jurisdiction. For example, a rule by the Environmental Protection Agency (EPA) regulating industrial emissions would not directly impact a restaurant owner unless they operate in an affected industry.
Summary
On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the CY2026 Physician Fee Schedule (PFS), outlining new payment policies for clinicians and other providers. The rule sets Medicare Medicare's service payment structure and covers several key areas: physician payments, telehealth updates, specialty care models, and quality programs such as the Medicare Shared Savings Program (MSSP) and the Quality Payment Program (QPP), with negative impacts on health equity.
Impact Analysis
Legal Challenges
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Take Institutional Action
Organizations that might be affected by the proposals are encouraged to submit comments. Comments should highlight the potential negative effects of removing health equity adjustment scoring and the "Screening for Social Drivers of Health" measure.
Entities that received increased payments due to health equity adjustment scoring should provide comments explaining the financial impact and possible outcomes of such resource redistribution. If relevant, these entities should also identify any potential cost increases and patient implications from the removal of health equity adjustments.
Associated or Derivative Policies
OBBB, H.R. 1 - temporary, one-year 2.5% update in conversion factors
Policy Prior to 2025
CMS CY2025 PFS Final Rule
