Medicare Physician Fee Schedule 2026: What Medtech Innovators Should Know

What's New in the 2026 Medicare Physician Fee Schedule and Why It Matters for Medtech Innovators

Each summer, CMS releases a proposed update to the Medicare Physician Fee Schedule (MPFS), and while it may not grab headlines, this rule has ripple effects far beyond Medicare. Many commercial payers and health systems reference or align with Medicare’s fee schedule amounts, so that even a subtle policy shift can impact market access planning for medtech companies launching new products and services.

This year’s proposed rule for calendar year 2026 is packed with signals for companies working at the intersection of technology, chronic disease, and value-based care. If you're innovating in digital health, software-enabled devices, or chronic care management (and you don't want to read the 1,800 page document), read on for some highlights.

Remote Therapeutic Monitoring

CMS is taking a more cautious and structured approach to valuing Remote Therapeutic Monitoring (RTM) services. While the agency will maintain payment for existing RTM codes, it’s holding off on finalizing reimbursement for a newer group of RTM codes that involve only practice expense (PE). If you're not deep in Medicare lingo, PE refers to the non-physician costs associated with delivering a service—things like clinical staff time, equipment, and software licenses. For digital tools that aren’t tied to face-to-face visits or traditional staff time, figuring out a fair PE valuation can be tricky. CMS wants more real-world utilization data before committing to payment rates, which means companies offering RTM solutions—especially those designed to be used independently by patients—may need to wait a few more years before reimbursement fully catches up.

Paying for Software-as-a-Service (SaaS) and AI-enabled Technologies

Another area where CMS is asking for input: how to consistently and fairly pay for Software-as-a-Service (SaaS) and AI-enabled technologies. Historically, the physician fee schedule wasn’t designed to handle tools that scale digitally rather than through traditional labor or facility-based resources. CMS is now inviting ideas for how to fix that—whether it’s using hospital outpatient data to inform payment or crafting new methodologies entirely. This is a pivotal moment for medtech companies offering virtual platforms, AI decision support, or continuous monitoring systems to help define the future of reimbursement.

CMS is also thinking more broadly about what qualifies as a reimbursable medical service. Should FDA-cleared digital therapeutics that treat chronic conditions have their own payment category? What about medically tailored meals, or asynchronous lifestyle interventions that support behavior change? These questions signal a growing openness to models of care that treat whole-person health outside the traditional clinic walls—and a real opportunity for innovators who are ready to engage with policymakers and prove clinical value.

Heart Failure and Low Back Pain Special Payment Models

CMS is also launching a new mandatory value-based payment model focused on heart failure and low back pain—two areas where care fragmentation is common and costs are high. The Ambulatory Specialty Model aims to reward physicians who follow evidence-based guidelines, coordinate care proactively, and reduce downstream costs. For medtech companies, this model creates fertile ground for tools that support adherence to care pathways, patient engagement, or real-time risk identification.

These proposed changes aren’t final yet, but they offer important signals for where the reimbursement landscape is heading. For medtech companies, especially those developing digital, AI-enabled, or home-based technologies, now is the time to assess where your product fits—and whether your current coding and coverage strategy will hold up in a rapidly evolving payment environment.

If you're wondering what these updates might mean for your specific technology, let's chat. Whether you're planning a launch, preparing investor materials, or navigating early adoption barriers, I can help you think through the implications of these policies and how to position your product for success.

Nicole Coustier is a medtech startup advisor and U.S. reimbursement consultant. Set up a time to talk here.