Review of the Challenges and Requirements of Becoming an APM Qualifying Participant, and the Potential Gains Under the 2026 Medicare Physician Fee Schedule
This Feature Article is brought to you by AHLA's Physician Organizations Practice Group.
- January 01, 2026
- Will Kaufmann , Coker Group
- Troy Koch , Coker Group
- Alex Kirkland , Coker Group
- Stephen Ross , Coker Group
On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule (Proposed Rule), opening the period for public comment through September 12, 2025.1 The proposal details the updates to Medicare Part B payment policy effective January 1, 2026, and reflects broader efforts to enhance quality, efficiency, innovation, and recipient empowerment in health care delivery. This article highlights one cornerstone of the rule: the introduction of a separate conversion factor for the Qualifying Alternative Payment Model (APM) for Qualifying Participants (QPs).2 The CY 2026 PFS Final Rule was published on November 5, 2025, without material changes to the provisions of the Proposed Rule, other than a $0.02 change to the conversion factor, discussed in this article.3
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