CY 2027 Medicare Physician Fee Schedule Proposed Rule
On July 14, the Centers for Medicare and Medicaid Services (CMS) released proposed payment rates for physician services for calendar year (CY) 2027 outlining updates to Medicare payment policies and rates for physicians.
Here are the top takeaways:
1. Conversion factor flat, but GI payments decrease: In 2027, Medicare will continue to pay physicians differently based on whether they participate in an Advanced Alternative Payment Model (APM). Regardless of participation status, proposed physician payment rates will be lower because a temporary 2.5% payment increase enacted by Congress for 2026 is ending.
- The CY 2027 MPFS conversion factor for physicians who are part of a qualifying APM is expected to be $33.17 and $32.84 for physicians who are not. Compared to 2026, this represents a cut of 1% and 1.7%, respectively.
- Physician payments for GI endoscopy services performed in ambulatory surgery centers (ASCs) and hospital outpatient departments are expected to decrease by 3%.
2. More cuts to GI loom as CMS targets “duplicative” payments: CMS proposes payment cuts for certain same-day office visits and procedures, claiming that some physician work may already be reflected in procedure payments. Under the proposal, the highest-paid service would be paid in full, while additional same-day services would be paid at 50%. If finalized, gastroenterologists who frequently bill an E/M visit with a procedure could see lower Medicare reimbursement. The summary linked below explains the proposal in more detail.
3. CMS values new endoscopic submucosal dissection (ESD) codes: CMS proposes physician work relative value units (RVUs) of 15.00 for upper gastrointestinal ESD and 16.38 for lower gastrointestinal ESD, reflecting the time, effort, skill, and intensity involved in performing these procedures. These codes will have the highest physician work value in GI endoscopy when they take effect in 2027.
4. CMS limits meaningful, specialty-specific quality reporting for GI: Starting with the CY 2029 performance period, MIPS Value Pathways (MVP) become mandatory for any gastroenterologist not participating in an Advanced APM. Alongside the MVP mandate, CMS is reshaping the entire MIPS quality measure inventory.
Two quality measures are proposed for removal:
- Q320 Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients.
- NHCR4 Repeat Screening or Surveillance Colonoscopy Recommended within One Year due to Inadequate Bowel Preparation.
This change would reduce the number of measures that are most applicable to the majority of gastroenterologists.
The GI societies have prepared a preliminary summary of key MPFS proposals and will keep you informed about opportunities to engage in the advocacy process and help fight payment cuts to GI services.
CY 2027 Hospital Outpatient Department and Ambulatory Surgical Center Proposed Rule
On July 2, CMS released the CY 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule, outlining updates to Medicare payment policies and rates for hospital outpatient and ASC services.
Here are the top takeaways:
1. ASC and hospital outpatient payment increase: An overall 2.4% payment increase is expected for ASCs and hospital outpatient departments that meet quality reporting requirements.
2. Cuts to most GI procedures: While overall payments to hospitals and ASCs will increase, CMS estimates aggregate ASC payments for many GI procedures would decrease by 2%. Payment cuts for some high-volume GI endoscopy codes would be as much as 8%.
3. Greater site-of-care flexibility for physicians: CMS will offer physicians greater flexibility to determine the most clinically appropriate setting by proposing to phase out the inpatient-only list and expand the ASC Covered Procedures List.
4. Significant changes to hospital 340B drug reimbursement: CMS proposes reducing payment for 340B-acquired drugs from ASP+6% to ASP-33.4%, while offsetting the reduction through higher payments for non-drug outpatient services to maintain budget neutrality.
5. Removal of follow-up colonoscopy quality measure: CMS proposes to remove the “Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients” measure from the ASC and Hospital Outpatient Quality Reporting Programs beginning with the 2027 reporting period (2029 payment determination), while retaining the Facility 7-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy measure.
The GI societies have prepared a preliminary summary of the proposed OPPS and ASC policies to gauge the impact on GI.
Resources
CMS Medicare Physician Fee Schedule Proposed Rule and Fact Sheets
2027 Physician Fee Schedule Proposed Rule
2027 Physician Fee Schedule Proposed Rule Press Release
2027 MPFS Proposed Rule Work and Practice Expense RVU Changes
2027 Physician Fee Schedule Proposed Rule Fact Sheet
2027 MPFS Proposed Rule GI and E-M Payment Changes
CMS Hospital Outpatient and ASC Proposed Rule and Fact Sheets
2027 OPPS/ASC Payment System Proposed Rule
2027 OPPS/ASC Payment System Proposed Rule Fact Sheet
2027 Hospital Outpatient Proposed Payment Changes
2027 Hospital Outpatient Top GI Code Proposed Payment Changes
2027 ASC Proposed Payment Changes
2027 ASC Top GI Code Proposed Payment Changes