CMS Issues Final 2026 Medicare Physician Fee Schedule

November 4, 2025

On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the Final 2026 Medicare Physician Fee Schedule (MPFS). Here are the key provisions pertaining to ABA services:

Carrier Pricing of ABA CPT Codes

CMS extended carrier pricing of the CPT codes for adaptive behavior/ABA services through 2026. That means that providers will need to continue negotiating reimbursement rates with payers.

Changes to Medicare Telehealth Coverage List and Process

Historically CMS has approved health insurance billing codes for telehealth delivery on either a provisional or permanent basis. CMS finalized its proposal from earlier in the year to designate all codes on its current telehealth list as approved permanently, though the agency reserves the right to remove codes from the list based on internal review or input from interested parties. CMS also shortened its process for approving codes for telehealth delivery and did away with the provisional designation. That means that effective January 1, 2026 all CPT codes for adaptive behavior/ABA services (97151-97158, 0362T, 0373T) will be on the permanent CMS telehealth list. Providers should be aware that even with that change, medical necessity still applies. It will continue to be necessary to check state health insurance laws and/or rules, state professional licensure laws and/or rules, and payer policies to determine if any of the CPT codes for adaptive behavior/ABA services may be delivered by telehealth in the state(s) in which services are provided.