The 2026 Proposed Rule for payment policies under the Physician Fee Schedule was published 7/16/2025, opening up a comment period until 9/12/2025.
Quick review of the proposed rule shows a projected Conversion Factor (CF) of 33.4209, amounting to a 3.3% increase over the 2025 CF of 32.3465, taking into account several adjustment factors.
The CF has declined the last five years in a row, so this represents a substantial reversal in course.
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In addition, 2026 will be the third year of a four year phased-in increase in the WORK component of the Relative Value Units (RVUs) for many of the psychology-related CPT codes (see Herz, G. I. (2024). Medicare reimbursement for psychologists).
| HCPCS | 2025 National Payment Amount (NPA) | 2026 Estimated NPA |
| 90837 | $154.29 | $167.10 |
| 90834 | $104.16 | $113.97 |
| 90832 | $78.93 | $85.89 |
| 90791 | $166.91 | $173.45 |
| 96139 | $33.64 | $35.76 |
| 96133 | $93.48 | $98.26 |
| 96137 | $35.90 | $37.10 |
| 96132 | $125.18 | $122.65 |
| 90785 | $14.23 | $14.71 |
| 96136 | $40.76 | $44.12 |
| 90853 | $28.14 | $30.41 |
Assumptions: (1) The CF remains the same in the Final Rule as reported in the 7/16/2025 Proposed Rule; (2) RVUs remain as reported in the proposed rule or unchanged from 2025; (3) values are the National Payment Amount, which will vary by geographic region; (4) values are for non-facility (i.e., office) reimbursement. Values are reported for the ten services most frequently provided by psychologists, plus group therapy (HCPCS 90853).
Based on the available numbers, analysis in the proposed rule estimates the combined impact of changes in the RVUs to result in a 3% increase in total allowed charges for psychologists from 2025-2026 (estimated 5% increase in non-facility-based reimbursement, -3% decrease in facility based reimbursement).
The proposed rule estimates $727 million in total allowed charges in 2026 for psychologists ($589 million non-facility, $138 million facility).
The anomalous decrease in HCPCS 96132 from 2025 to the projected 2026 value is due to decreases in Practice Expense (PE) (1.21 in 2025, 1.04 in 2026) and Malpractice (MP) components (.10 in 2025, .07 in 2026) of the RVU, reducing the 2025 total RVU of 3.87 in to 3.67 in 2026.
Sources: Federal Register; CMS.gov/files; Physican Fee Schedule