2027 Medicare Physician Fee Schedule: What the Proposed Rule Changes for Practices

Where the 2027 rule stands

CMS released the CY 2027 Physician Fee Schedule proposed rule on July 14, 2026, for services on or after January 1, 2027. It was published in the Federal Register on July 16, 2026, under file code CMS-1848-P, and the comment period closed on September 14, 2026. The CMS-1848-P page holds the proposed RVU files and a specialty impact table.

The final rule had not been posted when this article was written. CMS can change any proposal in the final rule, including the conversion factor, so treat the numbers here as planning figures.

What changed: the main proposals

1. A lower conversion factor

Starting in 2026, Medicare uses two conversion factors: one for qualifying APM participants (QPs) and one for everyone else. According to the CMS fact sheet:

CMS gives three reasons. The statutory update is +0.25% for non-qualifying clinicians and +0.75% for qualifying APM participants. CMS estimates a +0.53% adjustment tied to proposed work RVU changes. Against that, the one-year 2.50% increase that Public Law 119-21 gave for 2026 does not carry into 2027, which CMS says means current law requires a 2.50% reduction compared with 2026. The net result is the drop in the table.

Do not read the 1.68% as your practice’s change. The conversion factor is one multiplier; the RVUs for each code are also proposed to change, and the same-day visit, G2211 and practice expense proposals below move the total again, so some specialties would come out ahead of the average and others behind it. The specialty impact table on the CMS-1848-P page shows CMS’s estimate by specialty, and the checklist at the end of this article explains how to model your own numbers.

2. Same-day E/M visits with global procedures

CMS proposes to reduce payment when a separately identifiable office or outpatient E/M visit is furnished on the same day as a procedure with a 0-, 10- or 90-day global period, by the same practitioner. Under the proposal, the most expensive service, whether the procedure or the visit, would be paid in full, and every other procedure or E/M visit that day would be paid at 50%. These are typically the claims billed with modifier 25 on the visit, so dermatology, orthopedics, podiatry, pain management and other procedure-heavy offices should look closely.

3. G2211 becomes a modifier

The complexity add-on code G2211 would be replaced by a modifier appended to the E/M base code. CMS’s fact sheet says the modifier would raise payment for the visit by 16%, keeping the same percentage at every E/M level. A second modifier for Shared Savings Program ACO participants and LEAD Model participant providers would raise it by 32%. CMS used placeholder names for both modifiers, so the actual codes will come with the final rule.

4. Tighter remote monitoring rules

For remote patient monitoring (RPM) and remote therapeutic monitoring (RTM), CMS proposes that:

• RTM be furnished only to established patients;
• a separately reportable initiating visit be required when RPM or RTM starts;
• the services be paid only when done by clinical staff employed by the practice, not by contractors;
• the code values be updated to reflect lower expected device costs.

Practices that use an outside RPM vendor to do the monitoring work would need to change that arrangement or stop billing these codes, if the proposal is finalized.

5. Practice expense and other changes

CMS proposes to phase out, over several years, the step that ties specialty practice expense totals to survey data from 2007 or earlier, and to replace it with a “PE stabilizer.” It also asks for comment on whether the facility and non-facility payment difference is still appropriate. Other items in the fact sheet:

• RHCs and FQHCs: the in-person requirement for mental health visits would be waived through December 31, 2027, and payment for non-behavioral visits by telecommunication would be extended through the same date.
• Clinical labs: the Clinical Laboratory Fee Schedule phase-in allows reductions of up to 15% a year, starting in 2027 and running through 2029.
• MIPS: CMS’s press release says traditional MIPS would sunset beginning with the 2029 performance period, and clinicians would have until the end of 2028 to move to a MIPS Value Pathway (MVP). CMS proposes three new MVPs, and starting in 2027 each clinician would report at least one measure central to their specialty.

Who it affects

• Every practice billing Medicare Part B under the fee schedule. The conversion factor touches every service paid under it, and many commercial contracts are written as a percentage of Medicare rates, so check yours.
• Procedure-heavy specialties that often bill an office visit and a minor procedure on the same day.
• Primary care and other longitudinal care practices that bill G2211 today.
• Practices with RPM or RTM programs, especially those run with an outside vendor.
• RHCs, FQHCs and practices still reporting traditional MIPS.

What to do before January 1, 2027: a checklist

1. Watch for the final rule. When CMS posts it, compare the final conversion factor and policies with the proposal before you change anything.
2. Model your 2027 Medicare revenue. Pull 2026 Medicare volume by CPT code, apply the final conversion factor and RVUs, and see what moves.
3. Find your same-day visit and procedure claims. Count how often you bill an E/M with modifier 25 alongside a 0-, 10- or 90-day global procedure, and estimate the effect of the 50% rule.
4. Prepare for the G2211 change. If it is finalized, update charge masters, EHR order sets and claim scrubber edits so the new modifier goes on the E/M line instead of the separate code.
5. Review RPM and RTM arrangements. Confirm who does the monitoring work, whether they are employed by the practice, and whether each patient had an initiating visit.
6. Check commercial contracts tied to Medicare rates. Note which payers update on January 1 and which use a fixed year’s fee schedule.
7. Plan your MIPS path. Pick the MVP that fits your specialty now, so 2027 reporting is not a scramble.
8. Brief your billers and front desk. Make sure the team knows which edits change on January 1 and who signs off on new rules in the system.

Frequently asked questions

Sources

• CMS, Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (fact sheet), July 14, 2026.
• Federal Register, Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule, document 2026-14327, July 16, 2026.
• CMS, CMS-1848-P regulation page (RVU files and specialty impacts).
• CMS, press release on the CY 2027 proposals, July 2026.

This article is general information about a proposed federal rule, not legal advice. Figures are proposed and may change in the final rule.