Independent medical practices should begin planning now for the proposed 2027 Medicare Physician Fee Schedule. CMS released the proposed rule on July 14, 2026, with payment and billing changes that could affect reimbursement, documentation, remote monitoring, evaluation and management services, and revenue-cycle workflows beginning January 1, 2027.
The rule is not final yet, but waiting for the final version could leave practices with too little time to update charge capture, payer rules, staff training, and financial forecasts. Here are the proposals that deserve the closest attention.
Why the 2027 Medicare Physician Fee Schedule Matters
Medicare Physician Fee Schedule payments are built from relative value units for physician work, practice expense, and malpractice expense, then converted into payment amounts through a conversion factor. Even small changes to that factor or to individual service values can materially affect a practice with a large Medicare population.
The CY 2027 proposal also changes how certain services may be reported and paid. That means practices need more than a simple fee-schedule update. Billing teams should model the financial effect, identify affected codes, and test workflows before January.
1. Proposed Medicare Conversion Factors Would Decline
CMS proposes a 2027 conversion factor of $33.17 for qualifying Advanced Alternative Payment Model participants, a projected 1.19% decrease from the current $33.57. For clinicians who are not qualifying APM participants, the proposed factor is $32.84, a projected 1.68% decrease from $33.40.
The reduction is driven in part by the expiration of a one-year 2.5% increase that applies in 2026. The actual impact will vary by specialty, service mix, geographic adjustment, site of service, and participation status.
Practice action: Run a code-level reimbursement comparison instead of applying one percentage across all Medicare revenue. Focus first on high-volume codes and services with narrow margins.
2. Same-Day E/M and Global Procedures Could Face Payment Reductions
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 physician or another physician in the same practice.
Under the proposal, the most expensive service would be paid at 100%, while the other E/M visit or surgical procedure would be paid at 50%. If finalized, this policy could affect dermatology, orthopedics, ophthalmology, surgery, pain management, and other procedure-heavy specialties.
Practice action: Review same-day E/M and procedure patterns. Confirm that modifier 25 use is supported by clear documentation, then estimate the revenue effect of the proposed multiple-service reduction.
3. G2211 Could Become a Percentage-Based Modifier
CMS proposes replacing HCPCS code G2211 with a modifier that would increase payment for the associated office or outpatient E/M code by 16%. The goal is to apply the same percentage increase across all E/M levels instead of paying a flat add-on amount.
A second proposed modifier would increase the associated E/M payment by 32% for eligible practitioners participating in a Medicare Shared Savings Program ACO or the Long-term Enhanced ACO Design Model.
Practice action: Do not change billing yet. Monitor the final rule, payer guidance, and the final modifier descriptors. Begin identifying which clinicians and encounters could qualify so the transition can be tested quickly if the proposal is finalized.
4. Remote Patient Monitoring Rules May Become Stricter
The proposed rule would require remote therapy monitoring services to be furnished only to established patients. It would also require a separately reportable initiating visit when remote physiologic monitoring or remote therapy monitoring begins.
CMS further proposes allowing payment only when RPM or RTM services are performed by clinical staff employed by the practice, rather than contractors. CMS is also considering whether to bundle current codes and create four new HCPCS G-codes for remote monitoring.
Practice action: Inventory every person and vendor involved in remote monitoring. Confirm employment status, initiating-visit documentation, patient eligibility, device data, time records, and supervision. Practices that outsource monitoring should model the operational risk now.
5. New Opportunities for Chronic Care and Preventive Services
CMS proposes separate coding and payment for shared medical appointments, which may support group-based care for patients with chronic conditions. The agency also proposes payment changes affecting smoking and tobacco-use cessation services, screening, brief intervention and referral to treatment services, and advance care planning performed by clinical staff under direct supervision.
For Rural Health Clinics, CMS proposes recognizing Diabetes Self-Management Training and Medical Nutrition Therapy as qualified preventive services that can be paid as stand-alone billable visits. These policies signal continued attention to prevention, chronic-disease management, behavioral health, and coordinated primary care.
6. Certain RHC and FQHC Telehealth Flexibilities Continue Through 2027
The proposal includes conforming changes reflecting the Consolidated Appropriations Act, 2026. In-person visit requirements for mental-health services would not apply to services furnished through December 31, 2027. CMS also notes extended authority to pay Rural Health Clinics and Federally Qualified Health Centers for non-behavioral health visits delivered through telecommunications technology through the same date.
Telehealth policies remain highly dependent on provider type, service, patient location, technology, place of service, and payer. Review our guide to 2026 Medicare telehealth billing changes for the current foundation, then update it when the 2027 final rule is released.
Seven Steps Independent Practices Should Take Now
- Compare 2026 and proposed 2027 Medicare rates for the practice’s highest-volume codes.
- Review same-day E/M and global procedure billing by specialty, provider, and modifier use.
- Audit G2211 workflows and prepare for a possible modifier-based replacement.
- Map RPM and RTM operations, including initiating visits, staffing, contractors, devices, and documentation.
- Identify new service opportunities involving shared medical appointments, preventive care, and advance care planning.
- Update the 2027 implementation calendar alongside the FY 2027 ICD-10-CM changes and the CMS prior authorization requirements.
- Build a final-rule checklist so fee schedules, payer edits, EHR settings, staff education, and patient financial policies can be updated before January 1.
Frequently Asked Questions
Are these 2027 Medicare changes final?
No. The July 14, 2026 release is a proposed rule. CMS may revise, remove, or finalize provisions after reviewing public comments. Practices should prepare scenarios now but wait for the final rule and payer instructions before changing claim submission.
Will every practice experience the same payment decrease?
No. The effect depends on the practice’s specialty, Medicare patient mix, code distribution, geographic adjustments, site of service, and APM status. A code-level analysis is more useful than a single across-the-board estimate.
What should a small practice do first?
Start with the top 20 Medicare codes by volume and revenue. Compare proposed rates, identify services affected by policy changes, and flag workflows that require staff or technology updates.
Prepare for 2027 Without Putting Revenue at Risk
The proposed 2027 Medicare Physician Fee Schedule combines payment pressure with significant operational changes. Independent practices that forecast the impact early will be better positioned to protect margins, prevent coding errors, and implement the final policies without disrupting patient care.
Medical Accounting and Billing Services (MABS) helps independent practices strengthen coding, clean-claim submission, denial management, payer follow-up, and revenue-cycle performance.
Prepare your 2027 billing workflow before the final rule becomes an emergency.
Phone: +1 302-520-2410
Website: www.mabillings.com
Email: info@mabillings.com
