Highlights from the CY 2027 MPFS proposed rule

CMS released a draft copy of the calendar year (CY) 2027 Medicare Physician Fee Schedule (MPFS) proposed rule this week, offering a first look at its plans to update physician reimbursement and related policies next year.

As required by statute, the proposed rule includes two separate conversion factors (CF) for qualifying and non-qualifying alternative payment model (APM) participants. For CY 2027, the proposed CFs are $33.17 for qualifying APM participants and $32.84 for non-qualifying APM participants, representing projected decreases of 1.19% and 1.68% from CY 2026.

CMS is proposing to reduce payment when a separately identifiable office/outpatient (O/O) evaluation and management (E/M) visit is furnished by the same physician or practice on the same date as a 0-, 10-, or 90-day global procedure. When a surgical procedure and separately identifiable E/M visit are furnished on the same day, CMS is proposing to pay the higher-valued service at 100%, while similar services furnished on the same day would be paid at 50%.

The proposed rule also calls for several changes related to the O/O E/M visit complexity add-on code, HCPCS code G2211. Notably, CMS is proposing to transition G2211 to a modifier that can be appended to the associated E/M base code.

“This modifier would increase the payment of the associated E/M code by 16%, instead of a flat rate, maintaining an equal percentage increase across all levels of E/M codes,” according to the CMS fact sheet.

The rule includes multiple provisions concerning remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) services. Along with service valuation changes and other updates, CMS is proposing the following:

• Requiring RTM services to be furnished to only established patients
• Requiring practitioners who report RPM/RTM services to furnish a separately reportable initiating visit at the start of RPM or RTM services
• Allowing payment for RPM/RTM services only when clinical staff employed by the billing practice deliver them, rather than contractors

Other proposed updates include practice expense methodology changes, new HCPCS codes for advance care planning services, and more. Public comments on the CY 2027 MPFS proposed rule are due by September 14, 2026. Of note, CMS is seeking comments on code sets, primary care service valuation, and global surgery payment accuracy.