Payer Policy · January 15, 2026
2026 Medicare Physician Fee Schedule: What Dermatology Practices Need to Know
Short answer: The 2026 Medicare Physician Fee Schedule raised the conversion factor 3.26% for most practices, the first real increase in years. But dermatology didn't get a clean raise. A new 2.5% efficiency cut hit the work value of nearly every dermatology procedure, practice expense rules shifted money from facility-based to office-based care, and skin substitutes moved to a single flat rate. Whether your practice gained or lost in 2026 depends on your procedure mix and where you deliver care.
This article is part of the dermatology billing blog, where we cover coding, denials and payer policy as they change.
The 2026 rule took effect January 1, 2026. This guide explains what changed, why dermatology felt it differently from other specialties, which code families were affected, and what to check in your own numbers before 2027 begins.
What this guide covers:
- The key numbers at a glance
- How Medicare calculates dermatology payment
- The five 2026 changes that matter for dermatology
- Impact by code family
- How different dermatology practices fared
- Office vs facility payment
- Ripple effects on Medicare Advantage and commercial contracts
- What to do now
- Looking ahead to 2027
- FAQs
Updated October 2026. The 2027 look-ahead will be updated when CMS publishes the final CY 2027 rule.
The Key Numbers at a Glance
| Item | CY 2025 | CY 2026 (final) |
|---|---|---|
| Conversion factor, most practices (non-qualifying APM) | $32.3465 | $33.4009 (+3.26%) |
| Conversion factor, qualifying APM participants | $32.3465 | $33.5675 (+3.77%) |
| One-time statutory boost | None | +2.5%, for 2026 only |
| Efficiency adjustment | None | −2.5% to work RVUs of non-time-based services |
| Facility indirect practice expense | Same method as office | Work-based portion cut to half the office amount |
| Skin substitutes | Product-specific ASP-based rates | Single flat rate of about $127 per sq cm as incident-to supplies |
| Office E/M visits | Not subject to efficiency adjustment | Still exempt (time/MDM based) |
Sources: CMS CY 2026 final rule fact sheet, AAMC summary, King & Spalding summary.
$32.3465 → $33.4009
Conversion factor, most practices (+3.26%)
−2.5%
Efficiency cut to work RVUs of non-time-based services
½
Facility indirect practice expense: work-based portion cut to half the office amount
~$127 / sq cm
Skin substitutes: single flat rate as incident-to supplies
How Medicare Calculates Dermatology Payment
Every service on the Medicare Physician Fee Schedule is paid with the same formula:
Payment = [(Work RVU × Work GPCI) + (Practice Expense RVU × PE GPCI) + (Malpractice RVU × MP GPCI)] × Conversion Factor
| Component | What it measures | Why it matters for dermatology |
|---|---|---|
| Work RVU | Physician time, skill and intensity | Cut 2.5% for non-time-based codes in 2026, which includes most dermatology procedures |
| Practice expense (PE) RVU | Staff, supplies, equipment and overhead | Often the largest share of an office procedure's value; very sensitive to CMS methodology changes |
| Malpractice RVU | Liability insurance cost | Small share for most dermatology codes |
| GPCI | Geographic cost differences | The same code pays differently in Manhattan and rural Kansas |
| Conversion factor | Dollar value of one RVU | Set each year by law and budget neutrality |
Each code also has two practice expense values: non-facility (performed in your office, where you pay for staff and supplies) and facility (performed in a hospital or ASC, where the facility bills for those costs).
Illustrative example only: a hypothetical service worth 2.00 total RVUs, at a GPCI of 1.0, paid 2.00 × $32.3465 = $64.69 in 2025 and 2.00 × $33.4009 = $66.80 in 2026, a 3.26% increase. But if that service is a procedure whose work RVUs were cut by the 2.5% efficiency adjustment, its total RVUs fell slightly too, so the real increase was smaller. For a facility-based service, the practice expense cut could erase the gain entirely.
That's why the conversion factor alone never tells the whole story. RVU changes, site of service and same-day billing rules can move payment much more than the headline number.
The Five 2026 Changes That Matter for Dermatology
CMS finalized the CY 2026 rule (CMS-1832-F) on October 31, 2025. Five policies shaped dermatology payment.
1. A higher conversion factor, partly temporary
The conversion factor rose to $33.4009 for most practices. It combines a 0.25% statutory update, a 0.49% budget neutrality adjustment, and a one-year 2.5% increase added by Congress. That last piece applies to 2026 only, which is why the 2027 conversion factor is expected to fall.
For the first time, Medicare also uses two conversion factors: a slightly higher one ($33.5675) for clinicians who qualify through an advanced alternative payment model (APM), and the standard one for everyone else. Most dermatology practices use the standard rate.
2. The efficiency adjustment
CMS cut work RVUs and intraservice time by 2.5% for services that aren't time-based (King & Spalding summary). CMS's reasoning is that procedures get faster as techniques and technology improve. The 2.5% equals five years of the Medicare Economic Index productivity adjustment, and CMS plans to apply it again periodically.
For dermatology this matters because:
- Almost every dermatology procedure, including biopsies, destructions, shave removals, excisions, repairs and Mohs, is non-time-based, so all of them took the cut.
- Office E/M visits are time- or MDM-based and were exempt.
- The cut reduces the work RVU itself, so it carries into every future year until CMS revalues the code.
3. Site-of-service practice expense changes
CMS reduced the work-based portion of indirect practice expense for services billed in facility settings (hospital outpatient departments and ASCs) to half the amount allowed in office settings. The logic: hospital-employed physicians no longer carry most office overhead.
- Office-based dermatology generally held steady or gained slightly, since money shifted toward non-facility payment.
- Hospital-employed and facility-based dermatologists saw lower physician payments for the same codes. Before the rule was final, the AADA estimated about a quarter of dermatologists work in settings exposed to this cut.
4. Skin substitutes move to a flat rate
Starting January 1, 2026, most skin substitutes are paid as incident-to supplies at a single national rate instead of product-specific ASP-based prices. The final rule set about $127.28 per square centimeter, later corrected to $127.14 per sq cm. Biologics licensed under Section 351 of the Public Health Service Act stay on ASP-based payment.
Dermatology practices that treat chronic wounds or use skin substitutes after Mohs or excisions should confirm their 2026 payments reflect the new rate and that the application procedure codes are billed correctly.
5. Prior authorization for skin substitutes in some states
CMS's new WISeR model added mandatory prior authorization for certain services, including skin substitutes, in select states starting in 2026. Check whether your state is included before applying covered products to Medicare patients.
The net effect
In 2026, a higher conversion factor masked code-level cuts. An office-based medical dermatology practice likely came out ahead. A procedure-heavy or facility-based practice may have seen flat or lower Medicare payments despite the headline increase.
2026 Impact by Code Family
In 2026, every code got the conversion factor increase. What decided the net result was whether the code took the efficiency cut and where it was performed.
| Code family | Typical codes | Global period | 2026 efficiency cut | Net 2026 direction (office setting) |
|---|---|---|---|---|
| Office E/M visits | 99202-99205, 99212-99215 | None | Exempt | Up: full benefit of the conversion factor increase |
| Add-on G2211 | G2211 | None | Exempt | Up: billable with E/M for ongoing care of a serious or complex condition |
| Biopsies | 11102-11107 | 0-day | Yes | Roughly flat to modestly up |
| Destruction, premalignant | 17000, 17003, 17004 | 10-day | Yes | Roughly flat to modestly up |
| Destruction, benign | 17110, 17111 | 10-day | Yes | Roughly flat to modestly up |
| Shave removal | 11300-11313 | 0-day | Yes | Roughly flat to modestly up |
| Excisions | 11400-11471, 11600-11646 | 10-day | Yes | Roughly flat to modestly up |
| Repairs | 12001-13160 | 0- or 10-day | Yes | Roughly flat to modestly up |
| Mohs surgery | 17311-17315 | 0-day (add-ons ZZZ) | Yes | Roughly flat; larger work share means more exposure to the cut |
| Intralesional injections | 11900, 11901 | 0-day | Yes | Roughly flat to modestly up |
| Pathology | 88305, 88312 | No global | Yes | Depends heavily on professional vs technical billing |
| Phototherapy | 96910-96922 | No global | Varies | Mostly practice expense driven; office setting favored |
In a facility setting, the same procedure codes also took the indirect practice expense cut, which could turn a modest gain into a loss.
The exact change for each code depends on its RVU mix. Compare your top codes' 2025 and 2026 rates for your locality in the CMS Physician Fee Schedule Look-Up Tool.
If you want these rate changes applied to your claims, see our dermatology coding services.
How Different Dermatology Practices Fared in 2026
| Practice profile | Likely 2026 outcome | Why |
|---|---|---|
| Medical dermatology (psoriasis, eczema, acne, biologic monitoring) | Best positioned | E/M visits got the full conversion factor increase with no efficiency cut |
| General dermatology with a high procedure share | Modest gain or flat | Conversion factor gain partly offset by the efficiency cut on biopsies and destructions |
| Mohs and surgical dermatology | Flat or slight decline | Procedures carry large work RVUs, so the 2.5% cut takes a bigger bite |
| Hospital-employed or facility-based dermatology | Most likely to decline | Efficiency cut plus the facility practice expense reduction |
| Wound care and skin substitute users | Large change either way | Flat-rate skin substitute payment replaced product-specific pricing |
The volume effect
Small per-code changes add up in dermatology because a handful of codes are billed in very high volume. A practice billing thousands of biopsies and destructions a year can see a meaningful swing in annual Medicare revenue from a change of a few dollars per code. That's why tracking your top codes by volume and by dollars matters more than the headline conversion factor.
Office vs Facility: Why Site of Service Matters More Now
Most dermatology happens in the office, where the practice pays for staff, supplies and equipment and bills the higher non-facility rate. When the same service is performed in a hospital outpatient department or ambulatory surgery center, the physician bills the lower facility rate and the facility bills separately.
Since 2026, the gap is wider. CMS reduced the work-based portion of indirect practice expense for facility services to half of the office amount, on the theory that hospitals now carry many of those overhead costs.
| Practice model | 2026 effect | What to check |
|---|---|---|
| Independent, office-based practice | Generally neutral to slightly positive | Confirm 2026 payments reflect the non-facility rate on every office claim |
| Hospital-employed or provider-based clinic | Lower physician payment for facility-billed services | Whether compensation plans tied to wRVUs or collections account for the cut |
| Practices with ASC or hospital surgery time | Mixed: office codes steady, facility codes lower | Split revenue by place of service to see each effect |
Practical check: confirm that the place-of-service code on each claim matches where the service actually happened. POS 11 (office) pays the non-facility rate; POS 22 (hospital outpatient) and POS 24 (ASC) pay the facility rate. A wrong POS code either underpays you or creates an overpayment you'll have to refund.
Ripple Effects: Medicare Advantage, Commercial Contracts and Medicaid
The Medicare fee schedule sets the price floor for much of the market, so its changes rarely stay inside traditional Medicare.
- Medicare Advantage. Many MA contracts pay a percentage of the current Medicare fee schedule, so the 2026 increase, and the 2026 code-level cuts, flowed through automatically on January 1, 2026.
- Commercial contracts. Contracts written as "X% of Medicare" track the fee schedule. Check whether yours reference the current year's schedule or a fixed base year. A fixed base year means you didn't get the 2026 increase.
- Payment policies. Several commercial payers already reduce payment for E/M visits billed with modifier 25 or apply multiple-procedure reductions. Review each payer's current policy, since these often change mid-year.
- Medicaid. State Medicaid fee schedules are set separately, but many benchmark to Medicare. Check whether your state updated its rates for 2026.
Action: pull your top five payer contracts and note, for each, the fee schedule reference year, any modifier 25 or multiple-procedure language, and the renegotiation or termination window.
What Dermatology Practices Should Do Now
Review your 2026 results
- Compare paid vs expected. For your top 15 codes, compare what Medicare actually paid in 2026 with the 2026 fee schedule for your locality. Underpayments usually point to an outdated fee schedule in your system or a wrong place-of-service code.
- Rank your codes by volume and dollars. For most dermatology practices, E/M visits, biopsies, destructions and Mohs dominate. These are where small rate changes matter most.
- Compare 2026 with 2025. Look at Medicare allowed dollars per visit and per procedure for the same months in both years. This shows your real net effect, not the headline 3.26%.
- Split by place of service to see office and facility results separately.
Tighten documentation and coding
- Audit modifier 25 use. The E/M must address a problem beyond the decision to perform the procedure. It's a long-standing audit target and a likely focus of future payment policy. See our modifier 25 guide.
- Check biopsy and destruction coding. Confirm the right biopsy method code (tangential, punch, incisional) and correct units for 17000/17003/17004.
- Capture G2211 where it applies. It's an add-on for E/M visits that are part of ongoing care for a serious or complex condition, which fits much of medical dermatology.
- Review skin substitute billing against the 2026 flat rate and any WISeR prior authorization rules in your state.
Check your contracts
- Confirm commercial and MA rates match contract terms, especially contracts tied to a percentage of the current Medicare fee schedule.
- Note renegotiation windows for your top payers, since the 2027 conversion factor is expected to fall.
If your review turns up underpayments or denials, our dermatology denial management and appeals services can work them.
Prepare for 2027
- Read the final CY 2027 rule when it's published and load the new fee schedule before January 1.
- Model 2027 revenue using your 2026 volumes, so a fee schedule change doesn't surprise you in the first quarter.
Looking Ahead to 2027
The 2026 gains are partly temporary. In the CY 2027 proposed rule, released July 14, 2026, CMS proposed:
- A lower conversion factor: $32.8409 for most practices (−1.68%), mainly because the one-year 2.5% boost expires (CMS fact sheet).
- A same-day payment cut: when an E/M visit with modifier 25 is billed on the same day as a procedure with a 0-, 10- or 90-day global, the highest-valued service would be paid in full and every other service that day at 50%. A Milliman analysis for the AADA estimates this would reduce dermatology's fee schedule payments by about 7%, the largest dollar impact of any specialty.
- Expanded phototherapy coverage: 96920-96922 beyond psoriasis to other inflammatory and autoimmune skin diseases.
These are proposals. The final rule is expected in early November 2026 and takes effect January 1, 2027.
| Date | Milestone |
|---|---|
| October 31, 2025 | CY 2026 final rule published |
| January 1, 2026 | 2026 rates take effect |
| July 14, 2026 | CY 2027 proposed rule released |
| September 14, 2026 | Comment period on the 2027 proposal closed |
| Early November 2026 (expected) | CY 2027 final rule |
| January 1, 2027 | 2027 rates take effect |
Oct 31, 2025
CY 2026 final rule published
Jan 1, 2026
2026 rates take effect
Jul 14, 2026
CY 2027 proposed rule released
Sep 14, 2026
Comment period on the 2027 proposal closed
Early Nov 2026 (expected)
CY 2027 final rule
Jan 1, 2027
2027 rates take effect
Frequently asked questions
What is the 2026 Medicare conversion factor?
$33.4009 for most physicians (non-qualifying APM participants), up 3.26% from $32.3465 in 2025. Qualifying APM participants receive $33.5675, up 3.77%.
Did dermatology get a raise in 2026?
It depends on the practice. Office-based medical dermatology generally gained, because E/M visits got the full conversion factor increase. Procedure-heavy and facility-based practices gained less, or lost, because of the efficiency adjustment and the facility practice expense cut.
What is the efficiency adjustment?
A 2.5% reduction to work RVUs and intraservice time for services that aren't time-based, starting in 2026. It covers most dermatology procedures, including biopsies, destructions, excisions, repairs and Mohs. Office E/M visits are exempt.
Why are facility-based dermatologists paid less in 2026?
CMS cut the work-based portion of indirect practice expense for facility-billed services to half the office amount, reasoning that hospitals now carry much of the overhead.
How are skin substitutes paid in 2026?
Most are paid as incident-to supplies at a single national rate of about $127 per square centimeter, replacing product-specific ASP-based payment. Section 351 biologics remain on ASP-based payment.
Is the 2026 increase permanent?
No. The 2.5% statutory boost applies to 2026 only. The CY 2027 proposed rule would lower the conversion factor to $32.8409 for most practices.
Can dermatologists bill G2211 in 2026?
Yes, with an office E/M visit when the visit is part of ongoing, longitudinal care for a single serious or complex condition, such as many chronic inflammatory skin diseases. Documentation should show that relationship.
How do I know my practice's actual 2026 impact?
Compare Medicare allowed dollars per visit and per procedure for the same months in 2025 and 2026, split by place of service, for your top codes by volume and revenue.
Want to see what 2026 did to your own claims?
A free claims audit reviews a de-identified sample of your dermatology claims and returns a line-item findings report, including underpayments against the current fee schedule.
