Healthcare organizations are already building 2027 budgets, planning education, evaluating workflows, and preparing for another year of regulatory change. The challenge? Some of the Medicare policies that could affect those plans are still proposals.
CMS released the CY 2027 Medicare Physician Fee Schedule (PFS) proposed rule in July, with changes that could affect reimbursement, E/M services, remote monitoring, and everyday coding and documentation workflows. With the comment period now closed, organizations are waiting for the final rule—and trying to determine what deserves attention now versus what should wait.
The key is to prepare without implementing proposed policy prematurely.
Payment rates could shift.
CMS proposed conversion factors of $33.17 for qualifying Alternative Payment Model participants and $32.84 for practitioners who are not qualifying participants. Both would represent decreases from the current CY 2026 conversion factors. While these amounts are not final, practices can begin evaluating the potential financial impact.
Same-day E/M and global procedures could require a closer look.
CMS proposed reducing payment when a separately identifiable office/outpatient E/M service and a 0-, 10-, or 90-day global procedure are furnished on the same day by the same physician or a physician in the same practice. The highest-valued service would receive 100% payment, with other applicable services paid at 50%.
G2211 could change significantly.
CMS proposed replacing G2211 with a modifier that would increase payment for the associated E/M service by 16%. Another proposed modifier would provide a 32% increase for certain practitioners participating in specified accountable care arrangements.
Remote monitoring is also under review.
Proposed RPM and RTM changes address established patient requirements, initiating visits, and the use of clinical staff employed by the practice. CMS is also considering broader changes to how these services are structured and valued.
For now, organizations do not need to rewrite policies based on proposals. Instead, identify which provisions could affect your services, reimbursement, documentation, and workflows. Then, when the final rule arrives, your team already knows where to focus.
That preparation can also reveal areas where current processes deserve attention regardless of what CMS ultimately finalizes. BCA, Inc.’s auditing, education, and consulting services can help organizations evaluate existing coding and documentation practices, identify areas of risk, and translate finalized Medicare policy into practical next steps.
Preparing now does not mean predicting what CMS will finalize. It means being ready to act when we know.
Book your consultation today with one of our experts.