CMS Releases Proposed 2026 Medicare Physician Fee Schedule

July 17, 2025

On July 14, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the Notice of Proposed Rulemaking for the 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.

Proposed 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. In the July 14 notice, CMS announced that it is proposing a rule change to designate all of the codes on its current telehealth list as approved permanently, though the agency would reserve the right to remove codes from the list based on internal review or input from interested parties. CMS is also proposing to shorten its process for approving codes for telehealth delivery and to do away with the provisional designation.

At present, all of the CPT codes for adaptive behavior/ABA services (97151-97158, 0362T, 0373T) are designated provisional on the CMS telehealth list. If the proposed rule changes are finalized without revisions, presumably CMS will change that designation to permanent. If the proposed rules are not finalized, CMS indicated that it will conduct a comprehensive analysis of all provisional codes on its current telehealth list to determine which ones should be made permanent. 

The final 2026 Physician Fee Schedule will be issued on or around November 1, 2025. The Coalition will review that document and post a news item here about the status of CMS approval of our codes for telehealth delivery. Providers should note that (a) for now that approval remains provisional, and (b) even if CMS changes the designation to permanent, 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.