First Look at 2026 Draft Medicare Physician Fee Schedule Demonstrates Positive Steps Forward for Virtual Care, Says ATA Action

 ATA Action, the advocacy arm of the American Telemedicine Association, made initial comments on the 2026 Medicare Physician Fee Schedule (PFS) proposed rule posted by the Centers for Medicare & Medicaid Services (CMS).

“The telehealth and digital health provisions included in this draft rule clearly indicate strong commitment from President Trump, Secretary of the U.S. Department of Health and Human Services Robert F. Kennedy, Jr., and Dr. Mehmet Oz, Administrator for the Centers for Medicare & Medicaid Services, to modernize our healthcare system and integrate technology-enabled services to better reflect how care is delivered today,” said Kyle Zebley, executive director, ATA Action and senior vice president, public policy at the ATA. “At first glance, the CY 2026 Medicare Physician Fee Schedule reflects positive steps forward for virtual care in several key areas, including updates to the Medicare Diabetes Prevention Program, expansion of digital mental health treatment (DMHT) codes to include digital therapeutics for ADHD, and additional payment codes for remote monitoring. We are grateful to the Administration and encouraged to see that CMS is listening to stakeholder feedback and giving priority to ensuring patients have uninterrupted access to essential virtual care services.”

Key virtual care provisions in the 2026 PFS include:

• Changes to the Medicare Diabetes Prevention Program (MDPP), including ATA Action priorities:

Eliminating requirements for online-only MDPP suppliers to maintain in-person delivery capabilities through 2029
Extending temporary COVID-era telehealth flexibilities, including waivers for in-person presence through December 31, 2029

• Includes codes for 2-15 days of data collection over a 30-day period for remote treatment monitoring (RTM) and remote patient monitoring (RPM) services, and proposes reimbursement amounts for each code.
• Simplifies Medicare telehealth service list review process and proposes new payment codes to the telehealth list for CY 2026.
• Adopts permanent definition of “direct supervision” that allows real-time audio/video presence.
• Removes telehealth frequency limitations for subsequent inpatient visits, nursing facility visits, and critical care consultations.
• Expands last year’s groundbreaking new payment policies for DMHT services to include devices used in the treatment of Attention Deficit Hyperactivity Disorder (ADHD), if classified for use under 21 CFR 882.5801, and clarifies that the practitioner billing for a DMHT device need not be the practitioner who diagnosed the patient with a mental health disorder.

CMS is also seeking public comment on additional avenues for digital health reimbursement, including:

• Further expansion of the DMHT codes to include additional devices.
• Separate coding and payment for a broader based set of services describing digital tools used by practitioners intended for maintaining or encouraging a healthy lifestyle, as part of a mental health treatment plan of care.
• Coding and payment similar to DMHT codes for FDA-cleared digital therapeutics that treat or manage the symptoms of chronic diseases.
• Other digital device reimbursement policies and specifically creating a proposed new add-on G code to existing CPT codes to track use of an FDA authorized eye-tracking technology for diagnosing Autism Spectrum Disorder (ASD) in pediatric patients.

“The proposed rule, however, does not address a requirement that raises serious concerns around provider safety, administrative burden, and operational costs. A temporary COVID-era provision currently allows providers to report their affiliated practice address rather than their home address on Medicare billing and enrollment forms. We urge CMS to permanently allow providers to bill using their practice address in order to maintain the confidentiality and security of their home address, especially those delivering mental health services. It is imperative that this flexibility not be allowed to expire at the end of this calendar year,” added Zebley. “ATA Action will thoroughly review the just-released PFS and provide more detailed comments in the coming days and weeks. We are eager to continue working with CMS and the Trump Administration to ensure that the final 2026 PFS ensures continued access to essential virtual care services that support sustainable, quality healthcare delivery in communities across the U.S.”

About ATA Action

ATA Action recognizes that telehealth and virtual care have the potential to transform the healthcare delivery system by improving patient outcomes, enhancing the safety and effectiveness of care, addressing health disparities, and reducing costs. ATA Action is a registered 501c6 entity and an affiliated trade organization of the American Telemedicine Association (ATA).