Beginning in calendar year (CY) 2026, the conversion factor update for qualifying APM participants is +0.75%, while the update for nonqualifying APM participants is +0.25% (Final Rule fact sheet) . CMS identified that some physicians and practitioners received inaccurate Medicare payments as a result of how the updated conversion factor was initially applied.
CMS has corrected this issue and instructed Medicare Administrative Contractors (MACs) to reprocess affected claims.
If your practice was impacted, you do not need to take any action.
MACs will automatically adjust affected Medicare claims that were processed between January 1 and February 26, 2026. CMS expects that most claim adjustments will be completed by early May.
These adjustments may result in small increases in Medicare payments. In some cases, that may also lead to a corresponding increase in beneficiary cost-sharing amounts.
The Office of Inspector General (OIG) addressed this situation in a 2010 Policy Statement related to retroactive payment increases caused by new federal statutes or regulations.
Under this policy, providers, practitioners, and suppliers will not be subject to OIG administrative sanctions if they choose to waive beneficiary cost-sharing amounts that are directly attributable to these retroactive payment increases, provided the conditions outlined in the Policy Statement are met.
CMS has confirmed that this Policy Statement applies to claims impacted by the current QPP conversion factor correction.
Practices should monitor remittance advice over the coming weeks as MACs complete these adjustments, but no proactive outreach or claim resubmission is required. If you have internal policies related to cost-sharing waivers, this may be a good time to review them in light of the OIG guidance.
We’ll continue to share updates as CMS releases additional operational guidance.