2026 Health Policy Reset: How Primary Care Can Turn New Rules into Revenue

February 12, 2026

Leona Rajaee

For primary care practices, 2026 is not “just another MIPS year.” It’s a reset moment.

CMS is holding the MIPS performance threshold steady, introducing new payment models that reward longitudinal, team-based care, and shifting more dollars toward independent practices. At the same time, the Medicare Physician Fee Schedule (PFS) is finally starting to correct decades of under-valuation for primary care — with Elation joining a broad coalition to defend those gains.

This post breaks down what changed, why it matters, and how independent practices can turn these policies into durable revenue, not just regulatory noise.

1. Why 2026 Is the Year to Stop Treating VBP as Optional

On the surface, 2026 looks like a year of stability:

The MIPS performance threshold stays at 75 points through 2028.
Category weights remain unchanged.
Most of the change is at the level of new, retired, or tweaked measures, not a structural overhaul.

Underneath that stability, though, CMS has been clear about its trajectory: it wants 100% of attributed Medicare patients in some form of value-based contract by 2030. Traditional MIPS is being phased out by statute, to be replaced by MVPs and APM-aligned reporting.

Taken together, that means:

2026–2028 are your planning and repositioning years.
MIPS is no longer a destination — it’s a temporary on-ramp to ACOs and advanced alternative payment models (APMs).
Practices that use this window to modernize contracts, data flows, and workflows will be in a stronger position as more revenue ties directly to outcomes, complexity, and equity.

2. New Revenue Levers in the 2026 Physician Fee Schedule

The 2026 PFS tells a clear story: reward value, not just volume, and shift resources toward independent primary care.

Dual conversion factors and a boost for independent practices

CMS introduces dual conversion factors (CFs):

One, slightly higher CF for clinicians who qualify as Qualifying Participants (QPs) in Advanced APMs
A lower CF for those billing traditional fee-for-service only

At the same time, CMS adjusts practice expense:

Reduces facility practice expense,
Increases non-facility (office) practice expense, explicitly to boost independent primary care and other office-based care.

For small and independent practices, that’s real money — and a clear signal that policy is trying to pull dollars out of hospital-owned settings and back into community-based primary care.

The “efficiency adjustment”: correcting decades of mis-valuation

Historically, the PFS has undervalued primary care, behavioral health, and other time-based services, while non-time-based services benefited from efficiency gains that never translated into lower RVUs.

In 2026, CMS adds an “efficiency adjustment”:

A 2.5% reduction in intraservice time for many non-time-based services, to reflect productivity gains.
Evaluation and Management (E/M), care management, and behavioral health services are excluded, recognizing that these services have grown more complex and relationship-based, not more “efficient” in a way that justifies cutting time.

Elation joined a broad coalition — including primary care organizations, plans, and policy groups — in a sign-on letter to Congress urging lawmakers not to delay, block, or weaken this adjustment, because it starts to unwind long-standing distortions that undermined primary care.

Advanced Primary Care Management: from counting minutes to managing care

The rule also finalizes Advanced Primary Care Management (APCM):

A family of three HCPCS G-codes that bundle chronic care management (CCM), principal care management (PCM), and related communication services into a monthly payment.
Billing is based on the patient’s complexity and your team’s capability, not on minute-by-minute time logs.
Tiers reflect increasing clinical and social complexity, with higher payments as needs and risk grow.
Universal eligibility extends to physicians, NPs, PAs, and FQHCs/RHCs.

Paired with the ACCESS model — a voluntary, 10-year CMMI model launching July 5, 2026, where organizations are paid based on the share of patients meeting specific health targets — primary care can also earn a new co-management payment for reviewing updates from ACCESS partners.

Together, these changes move revenue closer to what primary care actually does: longitudinal, risk-stratified management of complex patients, often in collaboration with other clinicians and community partners.

3. Participation Pathways: From MIPS Survival to Value-Based Strategy

Instead of a binary “MIPS vs. ACO” mindset, 2026 lays out a ladder of participation pathways.

In practical terms:

Traditional MIPS
Best fit: clinicians not yet ready for downside risk or without an ACO home.
Revenue impact: up to ±9% on Part B claims based on Quality, Cost, Improvement Activities, and Promoting Interoperability.
MSSP ACO
Best fit: independent or system-based practices ready for population attribution.
Revenue impact: shared savings/losses plus potential QP bonus; 6+ quality measures required, with reporting via eCQMs/CQMs depending on ACO choice.
ACO REACH

Best fit: advanced risk-takers focused on equity and underserved populations.
Revenue impact: primary care or total care capitation and more aggressive risk/reward profile.
LEAD / AHEAD and APCM
Best fit: rural, independent, or safety-net practices needing cash-flow stability and advanced primary care teams already doing comprehensive care management.

The key is to stop asking “Should we do value-based care?” and start asking “Which path matches our risk tolerance, patient mix, and infrastructure today — and where do we want to be in three years?”

4. Turning Policy Into Practice: Contracts, Data, Tools, and Workflows

Policy only becomes revenue when it is wired through your contracts, data flows, technology stack, and practice workflows. That’s where many independent practices struggle — and where aligning with the right partners matters.

A realistic 2026 “reset” plan focuses on four areas:

4.1 Contracts: Know what you’re actually signing up for

From MIPS to MSSP ACOs to ACCESS and APCM, contract terms drive both opportunity and risk. Lessons from early VBP pioneers are clear:

Look for arrangements that offer prospective payments or stable monthly revenue instead of relying entirely on retrospective shared savings.
Analyze who else is in your ACO or network, and be cautious with shared-savings-only deals and overlapping quality programs that multiply reporting burden.

Your 2026 goal: every contract you sign has a clear line of sight to how your team will be paid, what data you’ll receive, and what success looks like.

4.2 Data and Technology: Treat information plumbing as revenue plumbing

AAFP’s Primary Care Information Blueprint, developed with advisory leaders including Elation’s Dr. Sara Pastoor and project partners Elation Health and Centene, lays out the essential data primary care needs to succeed in value-based care: accurate patient lists, transitions of care alerts, medication adherence data, cost/quality for referrals, and VBP-specific performance metrics.

The Blueprint emphasizes bidirectional data flow via health information exchanges (HIEs) and health data utilities (HDUs), rather than forcing physicians to pull piecemeal data from multiple portals.

In practical terms for 2026:

Make sure you receive and reconcile attribution lists for each payer.
Use your EHR and connected registries to capture eCQM/CQM data once, then reuse it for multiple programs.
Ensure ADT alerts, medication fill data, and cost/quality signals actually land inside the workflows your team uses every day.

4.3 Workflows and Documentation: Align the clinical story with the payment story

CMS and ACOs can’t pay you for work they can’t see. In a recent webinar we pointed to a simple but powerful checklist: understand contract requirements, identify the tools in your EHR that support those requirements, update documentation habits, and review metrics regularly across the performance year.

For independent primary care, that means:

Using templates and tools that make risk capture and care-gap closure part of normal care, not an after-hours project
Making sure social needs and care coordination work — especially under APCM and ACCESS — are documented in ways that flow into billing and quality reporting
Building simple routines to review dashboards for MIPS, ACO performance, and APCM panels on a monthly or quarterly basis

4.4 Governance and Partnerships: Don’t go it alone

Communication across CMS, ACO administrators, registries, practices, and EHR vendors is what turns regulations into executable plans.

Your practice doesn’t have to build everything from scratch — but you do need to:

Know who manages what (contracts, data aggregation, quality submission) for each program.
Have regular check-ins with ACO partners and your EHR vendor about measure support, registry feeds, and changes coming in 2027+.
Be willing to push back on arrangements that add complexity without a clear path to better patient care and sustainable revenue.

The Bottom Line

The 2026 policy environment is finally starting to line up with what primary care has always done best: longitudinal, comprehensive, relationship-based care that keeps communities healthier. Between a fairer PFS, APCM, ACCESS, stable MIPS rules, and clearer paths into ACOs and capitation, independent practices have more levers than ever to align mission and margin.

The reset isn’t about learning every acronym. It’s about making a few disciplined choices:

Pick the right participation pathway for your practice.
Wire your contracts, data, tools, and workflows to support that choice.
Partner with organizations — whether ACOs, registries, or technology companies like Elation — that are as committed to primary care’s role in the health system as you are.

Do that in 2026, and the next wave of policy change becomes less of a threat — and more of an opportunity to get paid fairly for the care you already believe in delivering.