On October 31, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the physician fee schedule final rule for calendar year 2026 (Final Rule). CMS is moving forward with several important provisions that impact how manufacturers and other stakeholders document and report BFSFs when calculating Average Sales Price (ASP) for Medicare Part B drugs. However, CMS declined to move forward with some of the previously proposed changes to the BFSF definition and the related fair market value (FMV) requirements. The summary below details the key BFSF and FMV provisions within the Final Rule and our thoughts on the impact to manufacturers both in the short and long-term.
The Final Rule is effective January 1, 2026, with the first ASP submission due on April 30, 2026 .
Please contact CJ DeKreek, Katherine Norris, or Kevin Lanier for more information and how we can support your FMV needs.
2026 Physician Fee Schedule (PFS) Final Rule Tearsheet:
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© Copyright 2025. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.
