CY 2027 PFS Proposals Making Headlines
The proposed 2027 payment cut wasn’t the only proposal that caught the attention of stakeholders and the trade press.
Key takeaways from the CY 2027 Medicare Physician Fee Schedule (PFS) Proposed rule include: a payment cut despite statutory updates; proposals to enhance primary care and incentivize participation in accountable care arrangements; a move away from traditional data sources and exploration of alternatives to CPT codes; the most significant revisions to the practice expense (PE) methodology in years; and a transition away from traditional quality reporting through the Merit-based Incentive Payment System (MIPS) and a focus on MIPS Value Pathways (MVPs) as the primary quality reporting framework.
Several proposals have made headlines.
Remote monitoring coalition and coordinated advocacy: Stakeholders have raised concerns about remote monitoring proposals, including a proposal to ban medical practices from using contractors to provide remote monitoring services, which could harm small and rural providers. Stakeholders have formed a coalition, Save Remote Monitoring. The Alliance for Connected Care is also convening stakeholders and coordinating advocacy.
Unbundling of maternity codes: Effective January 1, 2027, the American Medical Association (AMA) will replace the existing "global" maternity bundles with a more granular structure that separately reports antepartum care, labor management, delivery, and postpartum services. Critics argue that this change will increase costs for employer-sponsored health plans and Medicaid programs. The proposed rule includes 15 new HCPCS G-codes that would preserve the current bundled structure alongside the new unbundled CPT codes. The American College of Obstetricians and Gynecologists has raised concerns that the proposed G-codes would create a dual maternity billing system, worsening disparities and increasing confusion.
Pushback on payment cuts: The proposed CY 2027 qualifying alternative payment model (APM) conversion factor of $33.17 reflects a projected $0.40 (-1.19%) decrease from the current $33.57. Similarly, the proposed CY 2027 non-qualifying APM conversion factor of $32.84 reflects a projected $0.56 (-1.68%) decrease from the current $33.40. Physician groups immediately pushed back on the proposed pay cuts, arguing they do not keep pace with rising practice costs. A sampling of statements from physician groups is available HERE, HERE, and HERE. There is a call for Congress to implement comprehensive payment reform and, in the short term, to apply another short-term patch to avert a payment cut in 2027.
AMA and CPT in the crosshairs: The Centers for Medicare and Medicaid Services (CMS) called for public comment on the American Medical Association's (AMA) role in the rate-setting process and on the use of CPT codes. Numerous articles have examined how CPT has become the default coding standard, and the AMA's historical role as a critical source of data and recommendations in the fee schedule process.
Comments on the proposed rule are due by September 14. More information on the proposed rule is available HERE.
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For more information and questions, please contact:
Sheila Madhani
Madhani Healthcare Consulting
Email: smadhani@madhani-health.com
Tel: (202) 679-2977