Fee Schedules and CPT 2026: What to Load and Test Before the First January Claim

The first week of January is when a year of fee schedule and code set changes hits the claim form at once. The practices that have a quiet January did the work in December: loaded the codes, loaded the rates, tested a batch and fixed the templates. The ones that have a loud January find out on January 9 that the clearinghouse is rejecting a deleted code on every remote monitoring claim.

This is the checklist we run in December for the practices we bill for. It is longer this year because the Medicare fee schedule changed more than usual, because a rate CMS published on October 31 was corrected four weeks later, and because the telehealth rules have a January 30 expiration date sitting in the middle of the first quarter.

Key takeaways

• CPT 2026 brings 418 changes (288 new codes, 84 deletions, 46 revisions) effective January 1. Start with the deletions, because a deleted code in a live template rejects every claim that uses it.
• The Medicare conversion factor moves to $33.40 ($33.57 for qualifying APM participants), the efficiency adjustment trims work RVUs on procedures, and the skin substitute rate was corrected to $127.14 per square centimeter.
• The Part B deductible rises to $283 and the standard premium to $202.90; every estimate script that quotes a deductible needs the new number.
• Test a January batch through the clearinghouse in the last week of December and read the acknowledgements before the first live claims go out.

What changes on January 1, 2026

CPT 2026: the changes that hit office practices

The AMA describes the 2026 set as focused on digital health, artificial intelligence and minimally invasive procedures. Most of the 288 new codes are specialty procedures that an office practice will never report, and this is the part everyone skips: the 84 deletions matter more than the additions, because a deleted code in a live template produces a rejection on every claim that uses it, while a new code you never adopt costs you nothing until you decide to furnish the service. Start the review with the deletion list.

For the practices we work with, four areas matter most:

• Remote patient monitoring. New code 99445 reports device supply when monitoring covers 2 to 15 days in a 30-day period, alongside 99454 for 16 or more days, and new code 99470 reports the first 10 minutes of treatment management, alongside 99457 for the first 20 minutes. The existing codes 99453, 99454, 99457 and 99458 were revised to match. Practices with RPM programs need to review every patient's data-day counts against the new thresholds and update the charge rules, because patients who used to fall out at 15 days are now billable.
• Telemedicine. More codes were added to Appendix P (synchronous audio-video) and Appendix T (audio-only). Check payer acceptance of the telemedicine E/M codes 98000 to 98015 introduced in 2025; Medicare still does not pay them and continues to want the office visit codes with POS 02 or 10 and modifier 95 or 93.
• AI-assisted services. New codes describe services such as coronary plaque analysis and burn wound imaging with algorithmic analysis. Most are Category III or carrier priced; do not assume payment.
• Specialty blocks. The lower extremity revascularization family 37220 to 37235 is deleted and replaced by about 46 new codes built around lesion complexity and vascular territory, and the hearing device codes 92590 to 92595 are replaced by twelve new codes, 92628 to 92642, that follow the fitting pathway. Vascular and audiology practices should map every deleted code to its replacement before January.

The December checklist

1. Load the CPT 2026 set and end-date the 84 deleted codes at December 31, 2025. Then search every charge template, order set, superbill and favorites list for those 84 codes. This is where January rejections come from.
2. Load the 2026 Medicare fee schedule for your locality. Use the final rule addenda as corrected, not the proposed rule. Check the skin substitute rate reflects the November 28 correction. Confirm your practice management vendor's load date in writing.
3. Load commercial fee schedules that change on January 1. Contracts tied to a percentage of the current Medicare fee schedule inherit the new RVUs and the efficiency adjustment automatically; contracts with fixed rates need the new rate exhibit from the payer. Ask for it now. Without the allowed amounts loaded, you cannot detect underpayments in January.
4. Update patient responsibility estimates. Part B deductible to $283. Commercial deductibles reset. Every estimate script and every pre-visit letter that quotes a deductible needs the new number.
5. Re-test the claim scrubber. Run a January test batch through the clearinghouse in the last week of December using the new codes. Read the 999 and 277CA acknowledgements before the first live batch.
6. Review RPM and CCM charge rules. Time and data-day thresholds changed. A rule that fires only at 16 days is now leaving revenue on the table for 2-to-15-day patients.
7. Refresh the fee schedule review report. The report that compares allowed amounts to contracted rates should now compare to 2026 rates for January dates of service and 2025 rates for December.
8. Note the January 30 telehealth date and the January 15 WISeR date. Put a calendar reminder on January 20 to check whether Congress has extended the flexibilities again, and if you are in a WISeR state, have the first authorization requests ready for January 5.

A worked example: the RPM charge rule

A cardiology practice monitors 240 hypertension patients with connected cuffs. In 2025, about 180 of them transmitted on 16 or more days a month and were billed 99454; the other 60 transmitted on 5 to 15 days and were billed nothing for device supply, and their treatment management time was often under 20 minutes and also unbillable. From January, the 60 become 99445 candidates for device supply and 99470 candidates for treatment management of 10 to 19 minutes. At national Medicare rates that is a meaningful amount of monthly revenue the practice was already doing the work for, and the only change is a charge rule that reads the data-day count and the logged minutes correctly. The rule needs three branches now (under 2 days, 2 to 15 days, 16 or more) instead of two, and the time rule needs a 10-minute tier under the 20-minute one. Test both branches with a real December patient before January 1.

A note for practices with ASC or hospital outpatient work

The OPPS and ASC final rule, issued November 21 and effective January 1, raises payment rates 2.6 percent (a 3.3 percent market basket less a 0.7 percent productivity adjustment) and begins a three-year phase-out of the inpatient-only list with 285 mostly musculoskeletal procedures removed for 2026. It also expands site-neutral payment for certain services at off-campus provider-based departments. Surgeons whose cases move from inpatient to outpatient settings will see the professional claim unchanged but the facility, the authorization and the patient cost-sharing conversations change. Skin substitutes in the hospital outpatient department follow the same incident-to approach as the physician fee schedule, at the same corrected rate.

Questions we hear

Can we bill a deleted code for a December 31 service in January?

Yes. The code set is determined by the date of service. A service on December 31, 2025 uses CPT 2025 codes even if the claim is created on January 5. Make sure your system applies end dates by date of service, not by entry date.

Our commercial payer has not sent the 2026 rate exhibit. What do we load?

Load the 2025 rates as a placeholder and flag the payer. When the exhibit arrives, reload and re-run the variance report for January dates of service. Do not leave the payer with no rates loaded; you will miss underpayments.

What is the most common January mistake?

Templates. Every year, a deleted code survives in a charge template somewhere and goes out on dozens of claims before anyone notices the rejections. Search the templates. Our billing team runs this checklist for every practice in December, and the RCM training calendar includes a CPT 2026 session in the first week of January.

What to do this week

1. Pull the 84-code deletion list and search every template, superbill and favorites list for it.
2. Confirm in writing the dates your practice management vendor and clearinghouse will load CPT 2026 and the corrected 2026 Medicare fee schedule.
3. Request every missing 2026 commercial rate exhibit and load 2025 rates as placeholders where none has arrived.
4. Rewrite the RPM and CCM charge rules for the new thresholds and test them on a December patient.
5. Update the estimate scripts for the $283 Part B deductible and the January deductible reset, and schedule the test batch for the last week of December.