Payer Policy | CY 2027 Physician Fee Schedule Proposed Rule: Conversion Factor and Same-Day E/M Payment - Effective Date: January 01, 2027 (proposed)
Summary of the Rule or Edit Change
CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, 2026. The proposed conversion factors are $33.17 for clinicians who are qualifying participants in advanced APMs (down 1.19 percent from $33.57) and $32.84 for everyone else (down 1.68 percent from $33.40). The statutory updates are small, +0.75 percent and +0.25 percent, and CMS proposes a +0.53 percent work RVU adjustment. The drop comes from the one-year 2.50 percent increase in the CY 2026 legislation expiring.
Two other proposals will hit specialty clinics faster than the headline number. First, when the same physician furnishes an E/M visit and a global-procedure service on the same day, CMS proposes paying the highest-valued service at 100 percent and the others at 50 percent. That changes the math on every modifier 25 claim. Second, CMS proposes moving G2211 to a modifier format with a 16 percent payment increase, and it proposes changes to how practice expense RVUs are built, moving away from AMA survey data toward "more objective, routinely updated and auditable cost data."
On remote monitoring, the proposal would limit RTM to established patients, require a separately reportable initiating visit for RPM and RTM, require the work to be done by employed clinical staff rather than contractors, and it asks for comment on bundling RPM and RTM into new G-codes. CMS typically finalizes the PFS in the fall, so build your scenarios now, not in January.
Action Required for Billing Teams
- Model the same-day E/M cut. Pull 12 months of claims where an E/M with modifier 25 sits beside a global-period procedure, by provider. Re-price them at the proposed 100 percent and 50 percent split.
- Re-run the 2027 budget at both conversion factors. Use $32.84 for non-APM clinicians, and show the dollar gap against your 2026 collections by specialty.
- Audit your RPM and RTM programs against the proposed staffing and initiating-visit rules. If contractors do the monitoring work or patients enroll without a billable visit, flag the program now.
- Set a review date for the final rule. Assign one owner to read it the week it drops and update the charge master and payer-mix model before January 1.
Verifiable References
- CMS. Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (fact sheet). cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-...
- CMS. CMS-1848-P: Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B Payment Policies. cms.gov/medicare/payment/fee-schedules/physician/federal-regulation-no...
- Heart Rhythm Society. CMS Publishes Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule (summary). hrsonline.org/resource/hrs-publishes-cy2027-mpfs-proposed-rule/
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