Navigating Anesthesia Through CMS 2026 Fee Schedule Updates

CMS's 2026 Physician Fee Schedule finalizes structural and telehealth updates that will immediately affect anesthesia revenue and perioperative workflows. Anesthesiology leaders who bill Medicare should treat this as an operational mandate: the rule alters payment mechanics and incorporates telehealth policies previously used under emergency declarations into routine practice, producing near-term financial pressure and longer-term clinical flexibility. Department leaders must reassess billing and virtual workflows.

The rule creates separate conversion factors for qualifying Advanced APM participants and for other clinicians, replacing the prior single conversion-factor approach and establishing two parallel payment baselines tied to Advanced APM status versus nonqualifying clinicians.

That departure means attending anesthesiologists, CRNAs, and anesthesia groups in qualifying Advanced APMs will have payments calculated against a different conversion factor than colleagues who remain in fee-for-service, driving administrative segmentation by APM attribution and altering per-unit payments.

CMS set the qualifying APM conversion factor at $33.57 and the nonqualifying conversion factor at $33.40 while finalizing a –2.5% Medicare Economic Index efficiency adjustment for 2026, creating direct downward pressure on anesthesia revenue per case. Those dollar-level shifts translate into measurable revenue effects for high-volume procedures and for services with thin margins, increasing the incentive to review case mix, block scheduling, and provider staffing ratios. Department chairs should model revenue impact by specialty and prepare likely operational responses such as schedule compression or adjustments to CRNA/MD mixes.

CMS also made several telehealth flexibilities permanent, including removal of frequency limits for certain inpatient subsequent visits and authorization of real-time virtual direct supervision. These changes permit routine telesupervision during perioperative care, extended remote consults for critical care and postoperative assessments, and more flexible virtual follow-up visits in inpatient pathways—allowing virtual models to persist beyond emergency declarations.

On billing and documentation, the combined telehealth and conversion-factor changes require immediate updates: apply the correct conversion-factor–based fee schedule for Medicare claims, use the appropriate modifiers and place-of-service codes for virtual services, document the real-time audio/visual connection and supervising clinician involvement for virtual direct supervision, and retain verification records that support Advanced APM attribution for each billed clinician. Audit-ready documentation should include timestamps, participant roles, technology modality, and confirmation of APM participation where applicable. Billing teams must update templates and coder education without delay.

Strategically, anesthesia services should fold these reimbursement and telehealth changes into short-term forecasts and operational planning: revise revenue projections, reevaluate staffing models (including CRNA/MD mixes and on-call rosters), update perioperative telehealth protocols, and retrain billing staff on modifier and place-of-service requirements.

Key Takeaways:

• CMS implemented separate conversion factors for qualifying Advanced APM participants and for other clinicians, creating differential payment baselines.
• Dollar-level updates set qualifying APM CF at $33.57 and nonqualifying at $33.40, and a –2.5% efficiency adjustment applies in 2026.
• Permanent telehealth changes include removal of certain inpatient visit frequency limits and authorization of virtual direct supervision.
• Immediate actions: update billing templates, document virtual supervision rigorously, verify APM attribution, and retrain coders.