Radiology Business Management Association strongly urges Medicare to withdraw controversial doc pay ‘efficiency adjustment’
The Radiology Business Management Association is strongly urging Medicare to withdraw a controversial doc pay “efficiency adjustment” it says could exacerbate workforce shortages and patient access issues.
The federal payment program first proposed this 2.5%, across-the-board cut for physician services in July, exempting most time-based healthcare offerings such as 30-minute visits with primary care providers. Authorities at the time noted that only a small number of pay codes are considered for reevaluation annually, with docs gaining “efficiencies” from technology and other advancements, warranting cuts to account for these changes.
In a comment letter to CMS Administrator Mehmet Oz, MD, MBA, RBMA urged the agency to quash this proposal in the final 2026 Medicare Physician Fee Schedule. It contends such cuts lack empirical support, are arbitrary, and fail to account for increasing care complexity and rising practice expenses.
“RBMA urges CMS to reconsider this proposal, as it undermines Congress’ intent, adds unnecessary regulatory complexity, and risks worsening the radiologist workforce shortage and access issues for Medicare beneficiaries,” association leaders wrote Sept. 5. “The net effect of the proposed efficiency adjustment is to devalue physician work, which is yet another setback for physicians following decades of conversion factor reductions in the context of continuing inflation,” they added later.
The proposed rule posits that non-time-based codes will gain efficiencies “as they become more common, professionals gain more experience, technology is improved, and other operational improvements are implemented.” However, RBMA cited the example of CT exams, which once consisted of just 40 images but now regularly contains 400 or more. In addition, AI tools often flag findings that require additional review, potentially further hampering physician efficiencies. RBMA also noted that the agency’s estimates are based on flawed sources such as an outdated 2016 Urban Institute study. Plus, new technologies that have purportedly made radiologists more efficient—such as picture archiving systems (PACS)—come with costs not reflected in CMS practice expense estimates.
Based on its own initial calculations, RBMA believes Medicare is underestimating the impact of these efficiency adjustments. If CMS reduces the work relative value units (RVUs) for all non-time-based codes across healthcare settings, it does not seem possible this would result in a 0% pay impact for interventional radiology, nuclear medicine and radiation therapy centers in non-facility settings. After years of declining reimbursement, Congress and the White House had sought to provide relief in the spending bill finalized July 4, but this proposal would wipe out any such gains.
“The efficiency adjustment undermines the Trump administration’s stated objective to simplify and reduce regulations,” the letter reads. “The proposed efficiency adjustment adds complexity to the MPFS with no appreciable benefit to anyone and it fundamentally changes the MPFS in the absence of empirical data. There are many problems with the Medicare Physician Fee Schedule that need to be addressed; however, undervaluing physician work is not one of them. RBMA believes the efficiency adjustment is unreasonable, unsupported, and unnecessary.”
You can read the full letter to CMS here, which touches on other issues including updates to practice expense methodology and a proposal to make virtual supervision of imaging exams permanent. Those signing the message included RBMA Co-executive Directors Jessica Struve and Linda Wilgus, Board President Jamie Dyer, and Thomas W. Greeson, chair of the association’s Federal Affairs Committee. CMS is expected to release the final physician fee schedule in November.
Marty Stempniak has covered healthcare since 2012, with his byline appearing in the American Hospital Association's member magazine, Modern Healthcare and McKnight's. Prior to that, he wrote about village government and local business for his hometown newspaper in Oak Park, Illinois. He won a Peter Lisagor and Gold EXCEL awards in 2017 for his coverage of the opioid epidemic.