Hello Public Health Laboratory Community,
The Centers for Medicare and Medicaid (CMS) released the proposed Physician Fee Schedule (PFS) for calendar year 2026 on 7/16/25. Comments are due 9/12/25. https://www.federalregister.gov/documents/2025/07/16/2025-13271/medicare-and-medicaid-programs-cy-2026-payment-policies-under-the-physician-fee-schedule-and-other
Released in July every year, the CMS PFS Proposed Rule presents the reporting requirements that CMS eligible providers must meet to receive payments. Each provider is scored on how well they meet these requirements. CMS is changing the scoring for Public Health and Clinical Data Exchange for 2026 by limiting the points available to providers. For CY2026, there will only be points available for immunization registry reporting (25 points) and TEFCA exchange (5 points). Providers will not receive points for eCR, syndromic surveillance, or other registry reporting. CMS typically awards 25 points for eCR but is suppressing this score in CY2026 because CDC has temporarily paused much of the eCR program. CMS is also seeking feedback on transitioning to performance-based metrics for providers and the use of FHIR APIs in reporting these metrics.
The PFS is focused on the compliance of individual physicians; there are separate CMS rules and requirements for hospitals that have a more direct impact on laboratory reporting. Nevertheless, APHL plans to submit comments in response to the proposed rule to make several key points, including: 1) It is important to continue to invest in public health data exchange and modernization, including onboarding for eCR, the implementation of FHIR technology, and the adoption of TEFCA; 2) It is important to encourage providers to send data to public health by awarding bonus points for this reporting.
APHL is also collaborating with the Joint Public Health Informatics Taskforce (JPHIT) on a response from the JPHIT coalition of public health organizations.
We will share more information on our response as we continue to develop it. If you would like to share your thoughts on the PFS, please post them on ColLABorate, or reach out to me directly at melanie.kourbage@aphl.org.
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Melanie Kourbage
Lead Specialist, Informatics
Association of Public Health Laboratories
Bethesda MD
(240) 485-2747
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