Wakely’s analysis examines how proposed CY 2027 Medicare Physician Fee Schedule changes may affect reimbursement by provider specialty and geographic locality, including conversion factor, GPCI, RVU, and evaluation and management payment changes.
DOWNLOAD NOWCMS’s CY 2027 Medicare Physician Fee Schedule Proposed Rule includes proposed changes to payment rates, practice expense methodology, evaluation and management coding, and geographic payment factors.
Using national Medicare fee-for-service data and the Wakely Medicare Repricing Analysis Tool, Wakely estimates that the proposed changes would reduce average MPFS reimbursement by approximately 2.2% for non-qualifying participants.
The impact would vary substantially by provider specialty and Medicare locality. Orthopedic surgery and neurosurgery are among the specialties projected to experience the largest decreases, while licensed clinical social workers, clinical psychologists, and physical therapists in private practice are among those projected to see increases.
Key findings
- The proposed non-QP conversion factor would decrease by approximately 1.7%, primarily because the temporary 2.5% statutory payment increase for CY 2026 would expire.
- Proposed RVU and geographic changes would create additional downward pressure on reimbursement.
- CMS proposes replacing G2211 with a modifier that would transition the complexity add-on for eligible office/outpatient E/M services from a separate fixed-dollar payment to a 16% increase in payment for the underlying E/M service, or 32% for qualifying MSSP and LEAD participants.
- CMS also proposes reducing payment when an office/outpatient E/M visit occurs on the same day as a procedure with a 0-, 10-, or 90-day global period.
- The proposed changes to practice expense RVU methodology would be phased in over two years, with additional movement possible in CY 2028.
- Estimated payment changes vary by locality, ranging from a 3.6% decrease in Arkansas and Southern Maine to a 0.8% decrease in Atlanta.
- The analysis does not model the proposed same-day E/M and global procedure payment reduction or proposed RPM and RTM payment changes.
What this report covers
This report provides:
- An overview of the proposed CY 2027 MPFS conversion factors
- Analysis of proposed GPCI and RVU changes
- Implications of the proposed G2211 payment methodology
- Exposure to proposed same-day E/M and global procedure payment changes
- Estimated payment impacts by provider specialty
- Estimated payment impacts by Medicare locality
- Methodology, assumptions, and limitations
Who should read this report
This analysis is intended for:
- Health plans and Medicare Advantage organizations
- Provider organizations and medical groups
- Healthcare finance and reimbursement leaders
- Actuaries and payment analysts
- Government affairs and policy professionals
- Organizations negotiating or benchmarking Medicare-based reimbursement
Methodology note
Wakely repriced eligible claims from the 2024 Medicare 5% Sample Limited Data Set under the CY 2026 Final Rule and CY 2027 Proposed Rule fee schedules. Results reflect 2024 utilization patterns and should not be interpreted as a forecast of actual payment changes for every provider. The estimates are based on the proposed rule and may change when CMS publishes the final rule.
Download the report to understand how the proposed CY 2027 MPFS changes may affect reimbursement for your specialty and market.
