Conversion Factor: Proposed Cut
With the one-year 2.5% statutory increase for 2026 expiring, CMS proposes:
- Qualifying APM participants: $33.17, down from $33.57 (-1.19%)
- All other clinicians (non-QP): $32.84, down from $33.40 (-1.68%)
These figures reflect a +0.53% budget-neutrality adjustment and statutory updates of +0.75% (QP) and +0.25% (non-QP). They do not include the 2% sequester or potential 4% PAYGO cuts.
IPM Codes: Widespread Reductions vs. 2026
Most interventional pain codes are cut 1–6% in the office setting and 1-4% in Facility:
| Office Setting | Facility Setting | |
|---|---|---|
| Epidurals (62321 & 62323) | -3.0% to -3.3% | -2.7% to -3.0% |
| Transforaminal (64479 to 64484) | -3.7% to -4.9% | -1.2% to -3.8% |
| Facet joint (64490-64495) | -1.3% to -3.5% | -1.2% to -3.6% |
| Radiofrequency Ablation (64633-36) | -4.9% to -5.2% | -1.2% to -3.3% |
| SCS Lead Placement (63650) | -5.9% | -3.0% |
| EM Services (99203-205, 213-215) | 1.4% to -3.8% | -1.2% to -2.5% |
- Trigeminal nerve injection (64400): -19.9%; greater occipital nerve (64405): -16.6%
- Percutaneous SI joint fusion (27279, facility): -14.9%
- Kyphoplasty (22513–22515): -6.0% to -6.1%
- Spinal cord stimulator trial (63650): -5.9%; percutaneous
- PNS (64555): -6.3%
A handful of codes see small increases (e.g., blood patch 62273, several peripheral nerve blocks). The attached table shows every IPM code.
E/M Services: Major Change to Modifier -25
CMS proposes that when a separately identifiable office E/M visit is billed with modifier -25 on the same day as a 0-, 10-, or 90-day global procedure, only the highest-paid service is paid at 100% — all others, including the E/M visit, are cut 50%. This directly targets the common office-based scenario of a same-day evaluation and injection. CMS also proposes replacing add-on code G2211 with modifier MOD1, valued at 16% of the base E/M code (32% for ACO participants via MOD2). E/M payment rates themselves decline modestly (see attached table).
MIPS / Quality Payment Program
- Traditional MIPS would sunset with the CY 2029 performance period (2031 payment year), making MIPS Value Pathways (MVPs) the sole reporting option; three new MVPs are proposed.
- The quality measure inventory would be set at 180 measures (20 removals, 10 additions), with a new MIPS core measure reporting requirement replacing the outcome/high-priority measure requirement (small practices exempt).
- The performance threshold remains 75 points. Separately, the rule proposes refinements to the Ambulatory Specialty Model (ASM), the mandatory model whose low back pain cohort includes interventional pain physicians.
RFI: Duplicate Laboratory Testing, Imaging, and Interoperability
CMS is seeking input on mechanisms to address duplicate laboratory and imaging tests, including MAC edits resulting in non-payment or reduced payment, recoupment of payments, frequency limitations, and revised billing instructions, along with improved result sharing and interoperability. These policies could significantly affect pain practices that rely on imaging and drug testing. ASIPP will submit detailed comments — please send us your input.
Act Now
Comments are due September 14, 2026 (file code CMS-1848-P). Please review the attached documents and send your feedback to [email protected] so we can represent you forcefully. ASIPP will fight these cuts, as we always have — but your voice makes the difference.