2027 MPFS proposed rule: Sweeping changes in store for physician reimbursement
CMS is considering fundamental changes to how it pays for professional services, according to the 2027 Medicare Physician Fee Schedule (MPFS) proposed rule. The proposed rule, released July 14, describes numerous potential changes to payments, codes, coverage, and more.
CMS is proposing a reduction to physician fees for 2027 that would, in aggregate, lower payments across the board. The conversion factor (CF), one of CMS’ primary rate setting mechanisms, would drop between 1% and 2% depending on the professional fee setting. For practices that don’t operate as an alternative payment model (APM), the CF would drop by 1.7% to the amount of $32.8409. For those in APM situations, such as value-based payment models, the CF would fall by 1.2%, to $33.1693.
The separate anesthesia CF also drops across both groups, falling by 1.4% for non-APM participants and 0.9% for those in an APM. The chart below shows the differences between the 2026 CF levels and those that CMS is proposing for 2027.
CMS is considering major changes to Healthcare Common Procedure Coding System (HCPCS) add-on code G2211 (visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient's single, serious condition or a complex condition). The agency proposes two modifiers. The first modifier would be for general use and increase the base E/M code’s reimbursement by 16%. The descriptor would also be streamlined. The second modifier would be exclusively for participants in a Shared Savings Program or a Long-term Enhanced ACO Design (LEAD) Model ACO and would trigger a 32% increase to payments for the E/M service.
CMS is proposing to reduce payment when a separately identifiable E/M is performed by the same physician, or at the same practice, on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service would be paid at 100% and all other procedures or services furnished on the same day would be paid at 50%.
CMS is also considering an alternative way of calculating the practice expense (PE) relative value units (RVU) as part of its plan to transition away from reliance on AMA survey data.
The proposed rule includes several requests for information (RFI), notably one seeking feedback on discontinuing use of the AMA’s Current Procedural Terminology (CPT©) code set. Citing various with the CPT code set, including a monopoly by the AMA and conflict with the administration’s goals, the RFI asks whether, and how, the agency could move away from the CPT code set. The agency is seeking input on the following specific topics:
- The pros and cons of using the ICD-10-PCS code set instead of the CPT code set
- Evidence of “harms or challenges associated with AMA’s monopoly over CPT-4 licenses for health care entities”
- Evidence that creation of CPT codes “follows a process of identification of medical necessity”
- Possible alternatives to the AMA’s CPT and RVS Update Committee’s processes
CMS is also proposing numerous changes to the Medicare Shared Savings Program, the Quality Payment Program, remote monitoring, new codes, and more.
Revenue integrity professionals should read the proposed rule carefully, paying particular attention to proposals that may directly affect their job duties, organizations, and communities. Reach out to colleagues in other departments who may be affected and discuss the potential impact. Consider submitting a comment and replying to one of CMS’ RFI. For tips on writing an effective comment, see NAHRI’s white paper Advocacy in Action: Commenting on Proposed Rules.
Editor’s note
A version of this article originally appeared on Part B News.