The Radiology Business Management Association (RBMA) has sent a letter to the Centers for Medicare & Medicaid Services (CMS), voicing the organization’s recommendations on the 2026 Medicare Physician Fee Schedule (MPFS) Proposed Rule.
In the letter, dated September 5 and available on the organization’s website, the RBMA offered discussion for each recommendation.
The RBMA asked that CMS allow specialty physicians, including radiologists, to participate in alternative payment models (APMs) to qualify for the higher conversion factor, acknowledging the “vital role” specialists play in patient care.
Noting that it supports the Prompt and Fair Pay Act, the RBMA requested that Medicare Advantage plans reimburse these providers at the higher conversion factor, and it also requested that the CMS provide clear guidance on processing claims and the determination of conversion factors.
The RBMA offered criticism in the letter for the proposed 2.5% “efficiency adjustment,” which it urges the CMS to withdraw, citing concerns about its negative effect on both reimbursement for physicians and patient care access:
“The adjustment is arbitrary and not resource based, misapplies economic productivity metrics to clinical practice, and fails to account for increased complexity, after hours demands and rising practice expenses – particular in radiology. RBMA urges CMS to reconsider this proposal, as it undermines Congress’ intent, adds unnecessary regulatory complexity, and risks worsening the radiologist workforce shortage and access issues for Medicare beneficiaries.”
RBMA also called the proposed site of service payment differential “not evidence-based or supported by data,” asking that CMS work with physicians to develop “data-driven, evidence-based solutions” in lieu of this policy.
Read the letter on RBMA’s website.
