Guide

The annual fee review in one afternoon

Summary

Review your fee schedule once a year, on a fixed calendar date, not in response to a bad month. Pull your top 20 codes by volume, check this year's Medicare Physician Fee Schedule amount against last year's, compare your charge to your highest contracted allowable, and raise any charge sitting below 150-200% of that allowable. Budget one afternoon.

By Gale Editorial · Updated 2026-07-26. Every figure cited to a dated source. How we write.

How often should you actually do this?

Once a year, on a fixed calendar date you pick in advance — not triggered by a slow month, a rent increase, or a competitor's rumored rates. Tie it to something external you already have to check: the new Medicare Physician Fee Schedule takes effect January 1 each year after CMS finalizes the annual rule, so late December or early January is a natural anchor, since you're pulling the new conversion factor and RVUs anyway 1. A practice that reviews reactively tends to under-raise for years, then jump the number all at once — which reads to patients and payers alike as a shock instead of routine maintenance.

What to pull before you start

Gather three lists before you touch a single number, in this order: your highest-volume codes, this year's Medicare rate for each, and your actual contracted allowable from every payer you bill. Doing the lookups first keeps the review a data exercise instead of a guess, and it means the number you land on for each code is defensible if a payer or a future you asks where it came from.

  • Your top 20 CPT/HCPCS codes by volume from last year — pulled from your billing software or superbill log. These carry most of your revenue; everything else is noise for this exercise.
  • This year's Medicare Physician Fee Schedule amount for each code, looked up in CMS's public Physician Fee Schedule search tool by code and your locality 2. This is a lookup, not a guess — the tool returns the national and locality-adjusted payment amount, the RVUs, and the payment indicators for any CPT or HCPCS code 2.
  • Your current contracted allowable from each payer you're credentialed with, for the same top 20 codes — from your payer contracts or remittance history, not your memory of the negotiation call.

Set your charge against your highest allowable, not the Medicare rate

Your charge — the number on your fee schedule — should sit above every allowable a payer might apply to it, because a charge below an allowable caps what that payer can ever pay you regardless of the contract terms. A working rule many solo practices use: set the charge at 150-200% of your single highest contracted allowable for that code, so no future contract or self-pay rate gets clipped by a stale charge. This is a practice norm, not a regulation — there's no legal floor or ceiling on what you charge, only on what payers are obligated to pay. The Medicare rate is a reference point, not the target: it tells you where the floor tends to sit, since most commercial contracts price as a percentage of the Medicare Physician Fee Schedule.

The comparison table

Lay the three lists out side by side in a single spreadsheet, one row per code, so the gap between what you charge, what Medicare pays, and what your best contract pays is visible in one glance rather than scattered across three sources. The new-charge column is the only one you're actually solving for — everything else is a lookup you already did.

CodeLast year's chargeThis year's Medicare PFS amountHighest contracted allowableNew charge
99214from CMS lookup 2from payer contract/remit150-200% of allowable
90837from CMS lookup 2from payer contract/remit150-200% of allowable

Flag any code where your current charge sits below the highest allowable — that's a code actively capping your own reimbursement, and it moves first. Everything else moves on the annual cadence.

Where Medicaid and multi-state practices add a step

If you take Medicaid, pull that state's published fee schedule directly from the state agency — Florida's AHCA, California's DHCS, New York's eMedNY, and Texas's TMHP all publish current provider fee schedules and billing manuals on their own sites 3456. Medicaid rates typically sit well below Medicare's, so they rarely set your charge, but they belong in the same table so a payer mix shift doesn't surprise you mid-year. A practice licensed or billing in more than one state repeats the lookup per state — state Medicaid fee schedules are not interchangeable, and citing one state's amount for another is the kind of error that shows up first in a remit, not in your review.

Unit caps that quietly change the math

Before finalizing a rate, check whether any of your top codes carry a Medically Unlikely Edit — a CMS-published cap on how many units of that code one provider can bill for one patient on one date 7. An MUE doesn't change your per-unit charge, but it does change your revenue ceiling per code per visit, which matters if your review also touches how you package or bundle services. This is a five-minute check against the same CMS lookup you're already using 27, not a separate project.

After the number moves

Update your fee schedule inside your EHR or billing software the same day you finalize the table — a fee review that sits in a spreadsheet for three months while old charges keep going out the door defeats the point. If your self-pay or out-of-network patients see a posted price list, update that alongside the charge master so the two never drift apart. Diary next year's review date before you close the file.

Common questions

No — raise by exception, not by a flat percentage. Codes already priced well above every contracted allowable don't need to move; codes sitting close to or below an allowable need the larger increase. A flat across-the-board raise tends to over-correct on your already-healthy codes and under-correct on the ones actually losing you money.

Only up to your contracted allowable — a payer with a contract pays the lesser of your charge or the negotiated allowable, so raising the charge above the allowable does nothing for that payer. It matters for self-pay patients, out-of-network claims, and any future contract negotiated as a percentage of your charge rather than a flat rate.

Pull it from a recent remittance for that exact code and payer rather than the contract summary, since the summary sometimes lists a representative code that doesn't match your actual mix. If you can't find one in your last twelve months of remits, that code hasn't been billed to that payer recently enough to price against it yet.

No — this sets your charge master, which is the number you bill; a separate negotiation sets the allowable a contracted payer actually pays. The annual review tells you which payers are worth approaching for a rate increase, because it surfaces exactly where your allowable has fallen behind Medicare or your own charge.

An afternoon for the first pass, less after that — most of the first year's time goes into pulling the top-20 list and locating contracted allowables you haven't organized before. Once that table exists as a living spreadsheet, each year's update is mostly refreshing the Medicare lookup and checking for new allowables.

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References

  1. 1.Centers for Medicare & Medicaid Services (2026). Physician Fee Schedule. Centers for Medicare & Medicaid Services (CMS). linkThat the Medicare Physician Fee Schedule updates annually through rulemaking, anchoring the review cadence
  2. 2.Centers for Medicare & Medicaid Services (2026). Physician Fee Schedule Search. Centers for Medicare & Medicaid Services (CMS). linkThe lookup method for finding the current-year Medicare payment amount by code and locality
  3. 3.Florida Agency for Health Care Administration (2026). Florida Agency for Health Care Administration. Florida Agency for Health Care Administration. linkWhere Florida Medicaid providers find the current state fee schedule
  4. 4.California Department of Health Care Services (2026). California Department of Health Care Services. California Department of Health Care Services. linkWhere California Medicaid providers find the current state fee schedule
  5. 5.New York State Department of Health (2026). eMedNY. New York State Department of Health. linkWhere New York Medicaid providers find the current state fee schedule
  6. 6.Texas Health and Human Services Commission (2026). Texas Medicaid & Healthcare Partnership (TMHP). Texas Health and Human Services Commission. linkWhere Texas Medicaid providers find the current state fee schedule
  7. 7.Centers for Medicare & Medicaid Services (2026). Medically Unlikely Edits. Centers for Medicare & Medicaid Services (CMS). linkThat MUE unit caps are published by CMS and affect per-visit revenue ceilings independent of the per-unit charge

https://www.gale.care/for-providers/fs-annual-fee-review · 7 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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