CMS has proposed the 2027 Medicare Physician Fee Schedule, and none of it is final. The proposal most likely to cut a procedural practice’s collections pays 50% for every service except the most expensive when an office visit and a global-period procedure share a date. G2211 would become a modifier, and obstetric and sleep coding change on 1 January regardless.
CMS issued the CY2027 PFS proposed rule on 14 July 2026 (fact sheet) and published it in the Federal Register on 16 July (document 2026-14327). The comment period closed on 14 September 2026, and CMS is working toward a final rule. CMS says the resulting policies would take effect on or after 1 January 2027. Every figure on this page is proposed and will be updated when the final rule publishes.
This is a watch list for practice owners and billing managers: what would change how you bill, in order of how much it matters.
At a glance
- Same-day visit plus procedure: when a separately identifiable office visit and a 0-, 10- or 90-day global procedure happen on the same day, CMS proposes paying the most expensive service in full and everything else at 50%.
- G2211 becomes a modifier: a proposed 16% uplift on the E/M code (placeholder MOD1), and 32% for certain ACO participants (placeholder MOD2).
- Obstetric coding: CPT restructures maternity care on 1 January 2027; CMS has proposed how Medicare would pay for it and asked whether to keep the old structure with G-codes instead.
- Sleep testing: six new unattended sleep-testing codes replace the three home sleep test codes; CMS has proposed their values.
- Conversion factor: proposed $33.17 for qualifying APM participants and $32.84 for everyone else, down 1.19% and 1.68%.
1. Same-day E/M and a global procedure: all but the most expensive service at 50%
This is the proposal most likely to change what a procedural practice collects.
Per the CMS fact sheet (14 July 2026), CMS proposes that when a separately identifiable office/outpatient E/M visit is furnished by the same physician, or a physician in the same practice, on the same day as a procedure with a 0-, 10- or 90-day global period, the most expensive service that day is paid at 100% and all other surgical procedures or E/M visits that day are paid at 50%.
The mechanism is modifier 25. In the rule itself, this proposal sits under the heading “Proposed Changes to Payments Using Modifier-25” (Federal Register 2026-14327, 91 FR 43908). CMS explains that a stand-alone E/M on the same day as a global procedure is billable only when it is significant and separately identifiable from the procedure, and that those visits are identified by appending modifier 25 to the claim. If your practice bills modifier 25 with global procedures, this proposal is about you.
Three points practices miss on first read:
- It is not only the visit that gets cut. The reduction lands on whichever services are not the most expensive. CMS’s own example is a dermatology visit plus two lesion shavings: the higher-paid shaving is paid in full, and both the second shaving and the visit are reduced by 50% (91 FR 43908).
- More than one service can be reduced. With three services, two are reduced.
- It is not limited to one physician. “Same group practice” is in the proposal.
CMS made a similar proposal in the CY2019 proposed rule and did not finalize it. This time it asked for comment on whether a different reduction, such as 25%, would be more appropriate, and on whether the policy should extend beyond office/outpatient visits (91 FR 43909). It also asked how the policy should apply to an E/M visit on the same day as an intravitreal eye injection. That is a question, not a carve-out.
Who this reaches: OB/GYN, cardiology, pain medicine, dermatology, orthopaedics, ophthalmology, and anyone else where a visit and a minor procedure routinely share an encounter.
What to do with it: pull your own numbers now. How often did you bill an office visit with modifier 25 and a 0-, 10- or 90-day global procedure on the same date for the same patient last year, and what would the proposal have cost? That is a report, not a guess, and it tells you whether this is a rounding error or a budget line.
2. G2211 would become a modifier (placeholders MOD1 and MOD2)
CMS finalized separate payment for the office/outpatient E/M complexity add-on, HCPCS G2211, in the CY2021 final rule, and implementation was delayed by statute before payment began.
For 2027, per the CMS fact sheet, CMS proposes to transition G2211 to a modifier appended to the E/M base code. In CMS’s words, “placeholder modifier MOD1 will be replaced with a two-digit HCPCS modifier if finalized.” The modifier would increase payment on the E/M code by 16%, an equal percentage at every E/M level instead of a flat amount.
CMS also proposes a second modifier, placeholder MOD2, worth 32%, available only to practitioners in a Shared Savings Program ACO or Participant Providers in a Long-term Enhanced ACO Design (LEAD) Model ACO. CMS proposes that claims with MOD2 would feed Shared Savings Program beneficiary assignment and benchmark and performance-year expenditures, so it is not purely upside for an ACO.
Both are placeholders in a proposed rule; nothing here is billable today. CMS proposes to keep the current limits on billing the complexity add-on with modifier 25 (91 FR 43903).
Why this ranks second: the actual two-digit modifier is the one fact every E/M-billing practice must load into its system before the first January claim. If you use G2211 heavily on lower-level visits, also model the change: a flat add-on and a 16% uplift do not land the same way.
3. Obstetric coding changes in January; Medicare payment is still open
The coding change is settled. According to the AMA, the CPT 2027 maternity care restructure, effective 1 January 2027, deletes 17 codes, adds 12 and revises 6. It retires the global obstetric package in favour of four separately reported phases: antepartum, labor management, delivery and postpartum. Antepartum and postpartum care move to per-encounter E/M reporting. The AMA states that the RUC’s recommended values and utilization assumptions, submitted to CMS in February 2026, were budget neutral.
On timing, which is often misreported: ACOG recommends that health plans begin accepting E/M billing for antepartum visits, without limitations or preauthorization, no later than 1 September 2026, with HCPCS modifier TH appended to mark the visit as maternity care. That recommendation is addressed to payers, not practices.
The Medicare payment decision is not. In the proposed rule (beginning at 91 FR 43880), CMS:
- proposes adopting the new CPT codes, but refines the RUC’s utilization assumptions by removing four prenatal E/M visits and reallocating those work RVUs to the new labor and delivery codes, which CMS says would raise work RVUs for each labor and delivery code by about 15%;
- seeks comment on creating 15 HCPCS G-codes that would keep the current global structure and payment for Medicare, in place of the new CPT codes.
If CMS goes the G-code route, a practice could report obstetric care one way for Medicare and another for payers that follow CPT. Keep that in proportion. Medicare is health insurance for people 65 or older and for certain younger people with a disability, End-Stage Renal Disease or ALS (Medicare.gov), so for most obstetric practices the Medicare leg is a small share of maternity volume. Check your own payer mix before you plan around the G-code question. The change that reshapes an OB practice’s billing is the CPT restructure itself, which arrives on 1 January whatever CMS decides. We cover it in detail in 2027 maternity coding changes for OB/GYN.
4. Sleep testing: new codes on 1 January, proposed values from CMS
The AASM announced on 15 July 2026 that home sleep test codes 95800, 95801 and 95806 are replaced by six new unattended sleep-testing codes that separate technical services from professional interpretation. The proposed rule (91 FR 43888) describes three technical codes (set-up, data acquisition and technical analysis) and three professional codes (interpretation and report), each at low, moderate and high complexity, defined by recording channels and parameter categories.
CMS proposes the RUC-recommended values for five of the six codes and a lower work value for the high-complexity interpretation code. If you bill home sleep studies, both your code selection and your component billing change in January. Our home sleep test codes guide has the readiness checklist.
A payment percentage you can absorb. A deleted code you are still billing on 2 January is a denial.
5. Conversion factor: proposed down, by less than the expiring increase alone implies
There are two conversion factors: one for qualifying APM participants (QPs) and one for everyone else. Per the CMS fact sheet (14 July 2026):
| Current (CY2026) | Proposed CY2027 | Proposed change | |
|---|---|---|---|
| Qualifying APM participant | $33.57 | $33.17 | −$0.40 (−1.19%) |
| Non-qualifying | $33.40 | $32.84 | −$0.56 (−1.68%) |
Several things move at once. The statutory updates for 2027 are positive (+0.75% for QPs, +0.25% for everyone else), and CMS cites an estimated +0.53% adjustment for proposed work RVU changes. Pulling the other way, the one-year 2.50% increase that Public Law 119-21 provided for CY2026 does not carry into 2027, which CMS says effectively means current law requires a 2.50% reduction compared with 2026.
Plan against the proposed net: −1.19% or −1.68%, depending on APM status. A “2.5% cut” quoted elsewhere is the expiring increase on its own, not what CMS proposed.
6. Remote monitoring would get tighter
If remote physiologic monitoring (RPM) or remote therapy monitoring (RTM) is part of a chronic care program, per the CMS fact sheet CMS proposes to:
- furnish RTM only to established patients;
- require a separately reportable initiating visit at the onset of RPM or RTM;
- pay only when services are performed by clinical staff employed by the practice, not contractors;
- update how the services are valued, on CMS’s understanding that devices may cost less than first estimated.
CMS also asked for comment on bundling the RPM and RTM codes into four new HCPCS G-codes, citing OIG recommendations. The contractor restriction is the one that breaks business models rather than trimming payment. If a vendor supplies your monitoring staff, get an answer in writing now on whether that arrangement survives.
7. Cardiology and pain medicine: the Ambulatory Specialty Model
The CMS Innovation Center’s Ambulatory Specialty Model, finalized in the CY2026 PFS final rule, is a mandatory model with five performance years from 1 January 2027 through 31 December 2031, focused on heart failure and low back pain. The CY2027 proposed rule proposes technical refinements, including participant exceptions and quality measures (Federal Register 2026-14327, section III.D). For cardiology and pain practices, “mandatory” is the word to note.
8. Practice expense starts moving off old survey data
Per the CMS fact sheet, CMS proposes to phase out, over several years, the step that keeps practice expense RVUs by specialty consistent with practice expense per hour data from 2007 or earlier, replacing it with a “PE stabilizer” meant to limit short-term swings. CMS is also asking whether the facility versus non-facility payment differential remains appropriate. Specialty-level PE is where payment shifts between specialties without a headline number changing; track it rather than react to it.
9. Global surgery and the smaller items
Global surgery data collection. CMS proposes to pause the post-operative visit data collection required by section 523 of MACRA. It states it has several years of data showing post-operative visits during the global period are not occurring while providers are still paid for them, posted a public use file of imputed post-operative visit RVUs, and invited comment on revaluation for future rulemaking. The proposal does not revalue global packages for 2027, but practices with heavy 10- and 90-day global volume should expect this to return.
Shared medical appointments. No HCPCS code currently describes them; CMS proposes separate coding and payment.
Behavioral health. CMS proposes adding smoking and tobacco cessation and SBIRT services to the final year of the four-year work RVU transition for timed behavioral health codes.
Advance care planning. CMS proposes two new HCPCS codes for ACP furnished by clinical staff under direct supervision, and proposes that ACP CPT codes 99497 and 99498 report only time personally spent by the billing practitioner.
RHCs and FQHCs. CMS proposes conforming changes so in-person visit requirements for mental health visits do not apply to services through 31 December 2027, and notes the Consolidated Appropriations Act, 2026 extended payment for non-behavioral-health telecommunication visits through the same date.
Clinical lab fee schedule. Beginning CY2027, payment reductions from private-payer-based CLFS pricing would phase in at up to 15% per year through CY2029.
Medicare eligibility. CMS proposes rules implementing section 71201 of Public Law 119-21, which limits Medicare eligibility to four groups. For a practice, that is a front-desk eligibility question.
Duplicate testing. CMS issued a request for information on duplicate laboratory and imaging testing and result sharing. It proposes nothing yet.
What to do now
- Run the same-day report. Count last year’s claims with modifier 25 on an office visit plus a 0-, 10- or 90-day global procedure, same patient and date, and price the proposed 50% reduction against them.
- Queue the G2211 change. Flag every template and charge rule that adds G2211 so it can be switched to the final two-digit modifier in one pass.
- Load the new CPT codes. Maternity and sleep codes change on 1 January 2027 regardless of the final rule. Update fee schedules, charge masters and order sets now.
- Check your monitoring vendor. If contractors deliver RPM or RTM, get the arrangement reviewed against the proposal.
- Re-verify eligibility in January. Plan front-desk re-verification for the proposed Medicare eligibility changes and for patients whose coverage changes on 1 January.
- Watch for the final rule. We will update this page when it publishes.
Frequently asked
Is the 2027 Medicare conversion factor going up or down?
CMS has proposed a decrease: $33.17 for qualifying APM participants and $32.84 for everyone else, against current factors of $33.57 and $33.40, down 1.19% and 1.68% (CMS fact sheet, 14 July 2026). The statutory updates are positive, but the 2.50% one-year increase for 2026 does not carry forward.
Will I still get paid for an office visit on the same day as a procedure?
Under the proposal, yes, but not always at full value. The most expensive service that day would be paid at 100% and all other services at 50%, including when the visit and procedure are furnished by different physicians in the same group practice. The rule ties the proposal to visits billed with modifier 25.
Does G2211 go away in 2027?
Not under this proposal. CMS proposes converting it to a modifier that increases the E/M payment by 16%, with a separate 32% modifier for certain ACO participants. Neither modifier exists yet.
Is the global obstetric package really ending?
Under CPT, yes: the AMA’s 2027 code set deletes the global maternity codes on 1 January 2027. How Medicare pays is still open. CMS proposed adopting the new codes with adjusted values and asked for comment on 15 G-codes that would preserve the current structure for Medicare.
Can I still comment on the proposed rule?
No. The comment period closed on 14 September 2026.
When do the changes take effect?
CMS says the policies would apply on or after 1 January 2027, once finalized. We will update this page when the final rule publishes.
Can someone handle this for us?
That is the job. AMS Solutions has billed for practices since 1992, with AAPC-certified coders and a dedicated team. We sign a BAA for covered services and work on a transparent percentage of collections, so our incentive matches yours. See our medical billing services, browse coding references in our resources library, or book a call.
This page is general information about proposed federal payment policy, not legal, coding or compliance advice. Proposals described here may be modified, dropped or finalized differently. Verify against the final rule before making billing decisions.