Review CMS's CY 2027 Medicare Physician Fee Schedule Proposed Rule now and submit comments on the six changes most likely to affect your practice — payment cuts, E/M and G2211 policy shifts, and remote monitoring rules — before the September 14, 2026 deadline.

Each year, the Medicare Physician Fee Schedule shapes how Centers for Medicare & Medicaid Services (CMS) pays private practices, making the agency’s proposed updates more than just another regulatory announcement. Most recently, the calendar year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule includes several significant policy changes that could affect physician reimbursement as well as quality reporting and the financial health of medical practices. While the rule isn’t final, CMS is accepting public comments before making its decisions—giving physicians and practice leaders an opportunity to influence the policies that will impact their patients and businesses. 

The public comment period gives providers and practice leaders an opportunity to share real-world perspectives before CMS issues the final rule. Feedback from clinicians can help identify unintended consequences, highlight implementation challenges, and recommend practical improvements that better support patient care and the sustainability of medical practices. By participating in the comment process, providers can help ensure that the final Medicare Physician Fee Schedule reflects the realities of clinical practice and addresses the needs of both providers and the patients they serve.

Comments on the CY 2027 Medicare Physician Fee Schedule Proposed Rule are due by 11:59 p.m. ET on September 14, 2026. To submit comments, visit Regulations.gov – CMS-1848-P Comment Submission. Here’s a press release about the rule for reference. 

CMS is accepting feedback from providers, practice leaders, professional societies, healthcare organizations, and members of the public. The agency will publish a final rule later this fall that will take effect on January 1, 2027. 

The CY 2027 Medicare Physician Fee Schedule Proposed Rule includes many topics that could directly affect private practices. However, here are six of the most important ones to review and consider.

In its CY 2027 Medicare Physician Fee Schedule Proposed Rule, CMS proposes to reduce Medicare payment when a physician (or another clinician in the same practice) furnishes a separately identifiable office/outpatient E/M visit on the same day as a procedure with a 0-, 10-, or 90-day global period. Under the proposal, Medicare would pay the higher-valued service at 100% and all additional same-day surgical procedures or E/M visits at 50%. What types of practices might feel the impact of this proposal most significantly? Specialties that frequently report modifier -25 with E/M services, including:

As you prepare comments on the CY 2027 Medicare Physician Fee Schedule, consider questions such as:

In its CY 2027 Medicare Physician Fee Schedule Proposed Rule, CMS proposes to reduce Medicare physician payment rates by lowering the Physician Fee Schedule conversion factor. For clinicians who do not participate in a qualifying Advanced Alternative Payment Model (APM), the proposed conversion factor would decrease from $33.40 to $32.84, a 1.68% reduction. For qualifying APM participants, the conversion factor would decrease from $33.57 to $33.17, a 1.19% reduction. 

Although the proposed reductions may appear modest, they come at a time when many private practices continue to face rising labor, supply, technology, and compliance costs. Because the conversion factor affects payment for nearly every service billed under the Physician Fee Schedule, even a small percentage decrease can translate into significant revenue losses over the course of a year. 

As you prepare comments on the CY 2027 Medicare Physician Fee Schedule, consider questions such as:

In its CY 2027 Medicare Physician Fee Schedule Proposed Rule, CMS proposes the first major update to the practice expense methodology in nearly two decades. Specifically, the agency proposes to incorporate newer data on clinical labor, medical equipment, supplies, and indirect practice costs to better reflect how physician practices operate today. However, while CMS frames the change as a modernization effort, the practical impact is that some specialties may see payment increases while others may see decreases.

As you prepare comments on the CY 2027 Medicare Physician Fee Schedule, consider questions such as:

For 2027, CMS proposes replacing HCPCS code G2211 with a modifier-based approach. The proposed modifier would increase payment for the associated E/M visit by 16%, replacing the current flat-rate add-on payment. In its CY 2027 Medicare Physician Fee Schedule Proposed Rule, CMS also proposes a second modifier that would provide a 32% payment increase for eligible clinicians participating in certain accountable care organizations (ACOs), recognizing the additional resources associated with longitudinal care and accountability for quality and total cost of care. 

As you prepare comments on the CY 2027 Medicare Physician Fee Schedule, consider questions such as:

In its 2027 Medicare Physician Fee Schedule Proposed Rule, CMS proposes several changes to Medicare’s remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) policies for 2027, including:

CMS is also seeking feedback on a potential restructuring of RPM and RTM coding, including replacing existing Current Procedural Terminology (CPT) codes with new HCPCS G-codes and creating a more standardized payment framework.

As you prepare comments on the CY 2027 Medicare Physician Fee Schedule, consider questions such as:

CMS seeks public input on whether it should reconsider its long-standing reliance on theAmerican Medical Association (AMA)’s CPT code development process and related valuation recommendations. CMS is asking stakeholders to comment on whether the current physician coding and valuation system—particularly the relationship between CMS, CPT, and the AMA/Specialty Society Relative Value Scale Update Committee—continues to be the best approach for Medicare payment policy. CMS is seeking feedback on potential alternatives that could improve transparency, competition, innovation, and accuracy in how physician services are coded and valued.

As you prepare comments on the CY 2027 Medicare Physician Fee Schedule, consider questions such as: