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2026 Medicare fee schedule includes policy lowering pathology and other specialists' pay

Next year’s Medicare Physician Fee Schedule was released late in the day on October 31. 

Despite strong opposition from the CAP and other medical specialties, the Centers for Medicare & Medicaid Services (CMS) is moving forward with several policy changes that will negatively affect pathology reimbursement. 

For pathologists: The CMS is applying “efficiency adjustments” based on its view that productivity gains are not fully captured in the physician work component of RVUs used to calculate payment. 

  • These reductions affect nearly all billed pathology services, including key CPT codes such as 88305, 88312, and 88341.
  • The CAP strongly opposed finalization of this policy, engaging with CMS, congressional leaders, and CAP members through grassroots efforts to highlight the flaws in the adjustment. Although the adjustment was finalized, the CAP will continue to advocate for reversal of this payment cut. 

The CMS did agree with the CAP to exclude time-based codes from the efficiency adjustment, that the time-based pathology clinical consultation codes (80503, 80504, 80505, and 80506) must be removed from this adjustment. 

Temporary relief: The One Big Beautiful Bill Act provided a temporary offset by increasing overall physician spending by 2.5% in 2026, resulting in an estimated 0.5% net increase in pathology reimbursement for 2026. The impact for an individual pathologist varies depending on case mix as the CMS' policies vary on a code-by-code basis.

  • The non-APM qualifying conversion factor for 2026 is finalized at $33.4009, a 3.3% increase from 2025, driven largely by this legislative adjustment.
  • The temporary pay increase helps for now, but the CAP continues to advocate to stabilize and reform the Medicare payment system. 

Go deeper: Review our impact table comparing changes to pathology services from current to next year’s payments.

  • In December, we’ll discuss these changes and more during a webinar, which we’ll formally announce in the coming days. 

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