Comments Provided to CMS Regarding 2026 Payment Policies Proposed Rule
As part of its commitment to advocating for ASRA Pain Medicine members and the pain medicine community, the Society recently provided formal comments to the Centers for Medicare and Medicaid Services (CMS) regarding its proposed rule CMS-1832-P, released on July 16, 2025. The proposed rule outlines significant changes to Medicare’s 2026 payment policies under the Physician Payment Schedule and other changes to Part B coverage policies.
View the letter here (PDF).
Conversion Factor (CF) Update Regarding Code G2211
The American Medical Association (AMA) estimates a $1 billion difference between CMS’s projected and actual utilization of the new Healthcare Common Procedure Coding System code G2211, designed to cover ongoing medical care related to a patient’s single, serious condition or a complex condition. Instead of accounting for 38% of all office visits, as CMS initially estimated, an AMA review of the first three quarters of 2024 Medicare claims data found that G2211 was reported with only 10.5% of office visits. Because of the need to maintain budget neutrality, this overestimation resulted in cuts to the Medicare CF. ASRA Pain Medicine is urging CMS to change the G2211 utilization estimate based on actual claims data from 2024 and use the difference to adjust the 2026 conversion factor in the forthcoming Medicare Physician Fee Schedule (PFS) Final Rule for 2026.
Valuation of New Codes for Percutaneous Interlaminar Lumbar Decompression
ASRA Pain Medicine is urging CMS to finalize the proposed work relative value unit (RVU) and practice expense inputs for two new Current Procedural Terminology (CPT) codes—62XX0 and 62XX1—in the final rule. These Category I codes, which describe percutaneous interlaminar lumbar decompression, were created in September 2024 to replace the Category III code 0275T.
Efficiency Adjustment Methodology
ASRA Pain Medicine is urging CMS to reconsider a proposed 2026 efficiency adjustment for establishing work RVUs, which would reduce Medicare payments by about 1% for most specialties. While CMS intends this adjustment to account for productivity gains and correct potential overpayment, the methodology is arbitrary, undermines the relativity of the fee schedule, and unfairly applies cuts even to recently reviewed codes. ASRA Pain Medicine contends that the policy lacks supporting data, risks misaligning with statutory requirements, and imposes ongoing, uniform reductions that do not reflect real-world variations in service complexity or physician workload.
Updates to Practice Expense Methodology – Site of Service Payment Differential
CMS has proposed revising the indirect practice expense (PE) methodology to account for site of service, which would lower PE RVUs for facility-based services and raise them for non-facility services—resulting in an estimated 7% payment cut in facilities and a 4% increase in offices. While CMS argues that facility-based physicians no longer bear significant indirect costs, ASRA Pain Medicine contends this assumption is flawed, noting that both independent and employed physicians still face substantial overhead such as staffing, billing, and prior authorization. The proposal could harm private practices, fuel consolidation, and misrepresent true costs. ASRA Pain Medicine is urging CMS to delay changes until better data is available.
G-code for Intraoperative Cryoablation Therapy for Postoperative Pain Management
CMS is considering whether to create a new G-code for intraoperative cryoablation therapy, which provides temporary postoperative pain relief and may reduce opioid use but adds 20–30 minutes of surgical time. While supportive of multimodal, opioid-sparing pain management strategies, ASRA Pain Medicine does not endorse establishing a G-code at this time, citing limited current use and insufficient evidence. Instead, they note that an existing Category III CPT code (0441T) could be used for tracking or reimbursement if CMS wishes to move forward.
Ambulatory Specialty Model – Low Back Pain
CMS has proposed a mandatory Ambulatory Specialty Model (ASM) for low back pain, running from 2027–2031, that would apply two-sided risk with payment adjustments of up to ±9% (increasing over time) based on performance, while exempting participants from the Merit-based Incentive Payment System (MIPS). Although ASRA Pain Medicine welcomes opportunities for specialists to join value-based care models, the Society has major concerns with the mandatory nature of participation, short preparation time, undefined performance thresholds, redistribution cuts that guarantee overall payment reductions, penalties exceeding MIPS limits, and unreliable cost measures. ASRA Pain Medicine also objects to requirements for formal collaborative care arrangements with primary care practices, urging CMS to refine attribution, comparability across specialties, and cost measure reliability before finalizing the model.