2027 MEDICARE PHYSICIAN FEE SCHEDULE (MPFS)
FINAL RULE RELEASED
Includes 2027 Quality Payment Program Final Policies
Final 2027 Conversion Factor:
$32.95 for Qualifying Alternative Payment Model (APM) participants
$32.63 for Nonqualifying APM participants
This afternoon, CMS released the CY 2027 MPFS Final Rule. CMS also released a press release, a physician fee schedule fact sheet, and a shared savings program fact sheet. The final rule takes effect on January 1, 2027. In its September 14, 2026, comment letter, ASCRS urged CMS to withdraw multiple harmful proposals, including the 50% payment reduction for same-day E/M visits billed with modifier -25 and the changes to the indirect practice expense methodology. In response to comments from ASCRS and others, CMS significantly scaled back its modifier -25 proposal but finalized the practice expense changes as proposed.
2027 MPFS Conversion Factor
As required by the MACRA statute, there are two separate conversion factors: one for qualifying alternative payment model (APM) participants (QPs), and one for physicians and practitioners who are not QPs. The update to the qualifying APM conversion factor for CY27 is +0.75%, and the update to the non-qualifying APM conversion factor for CY27 is +0.25%.
In addition to these updates, the conversion factor also includes a -0.12% budget neutrality adjustment. However, Public Law 119-21, which CMS refers to as the Working Families Tax Cut (WFTC) legislation, provided a 1-year conversion factor increase of 2.5% for CY 2026, which will no longer be in effect for CY 2027. Therefore, this requires a -2.5% reduction in the conversion factor for 2027. As a result, the final CY27 qualifying APM conversion factor is $32.95, and the final CY27 non-qualifying conversion factor is $32.63. This represents a 1.83% decrease from the 2026 qualifying APM conversion factor of $33.57, and a 2.31% decrease from the 2026 non-qualifying conversion factor of $33.40. The final conversion factors are lower than the proposed $33.17 and $32.84 because the budget neutrality adjustment changed from +0.53% in the proposed rule to -0.12% in the final rule.
The final CY27 Medicare payment for 66984 is $442.12, which represents a -4% reduction from 2026.
In its comments, ASCRS urged CMS to continue working with Congress on a long-term solution to Medicare physician payment, including an annual update that keeps pace with inflation.
Standalone E/M Visits and Global Periods (Modifier -25)
In the final rule, CMS finalized a scaled-back version of its policy to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician of the same specialty in the same group practice) on the same day as a 0-day global procedure (identified on the claim with modifier -25). The policy only applies to 0-day global procedures—CMS did not finalize extending it to 10-day or 90-day global procedures, as originally proposed. The most expensive service (either surgical or E/M visit) will be paid 100%, and all other same-day services will be paid at 80%.
This is a significant improvement over the proposal, which would have applied a 50% reduction to E/M visits furnished on the same day as 0-, 10-, or 90-day global procedures. CMS lowered the reduction to 20% and limited the policy to 0-day global procedures.
In its comment letter, ASCRS strongly opposed this policy. ASCRS has also joined the Same Day Care Coalition, a broad alliance of national physician and patient organizations, to fight it.
E/M Visit Complexity Add-On Code (G2211)
The use of the E/M visit complexity code, G2211, was implemented in CY 2024. CMS finalized two changes, which include transitioning G2211 to a modifier (modifier B1) that can be appended to the associated E/M base code, which represents a 16% increase in payment for the E/M code. In addition, CMS will recognize additional resource costs incurred by practitioners in ACOs when providing longitudinal care. This modifier (modifier B2) will be available for practitioners participating in a shared savings program, ACO, or participant providers in a long-term enhanced ACO design (LEAD Model ACO) and will increase payment for the associated E/M visit by 32%. Both changes were finalized as proposed.
Practice Expense Changes
CMS finalized its proposal to reform the way PE RVUs are assigned to specific services by reducing reliance on specialty-specific practice expense per hour (PE/HR) data. Beginning in 2027, CMS will phase out over 2 years the Indirect Practice Cost Index (IPCI), the part of the methodology that ensures the overall number of PE RVUs by specialty is consistent with the PE/HR data. The IPCI will be replaced with a PE stabilizer adjustment, which generally limits annual changes in a service’s PE RVUs to 5%. These changes were finalized as proposed.
ASCRS estimates that, once fully phased in, these changes will reduce practice expense RVUs for cataract surgery (66984) by 30% over 5–6 years. ASCRS will continue to fight this policy.
CMS also sought comment on whether the site-of-service payment differential between facility and non-facility settings is still appropriate. ASCRS urged CMS to repeal the 2026 reduction to indirect practice expense for facility-based services, noting that 70% of ophthalmologists remain in private practice and continue to maintain offices for pre- and postoperative care even when surgery is performed in an ASC or hospital. CMS did not repeal the 2026 reduction in this final rule but said it may consider comments about the site-of-service differential in future rulemaking.
Improving Global Surgery Payment Accuracy
CMS finalized its proposal to pause the reporting of CPT code 99024 (post-operative follow up visit) data collection required by MACRA, citing the undue burden of the reporting requirements on providers. CMS also sought comment on expanding data collection to all physicians, as well as additional data sources that could be considered. CMS did not expand the data collection.
Quality Payment Program
MIPS Value Pathways (MVPs)
CMS is officially sunsetting traditional MIPS and making MVPs mandatory beginning with the 2031 performance year/2033 payment year.
CMS received major pushback on the proposal to make MVPs mandatory beginning with the 2029 performance year. The finalized policy delays the implementation of mandatory MVPs by 2 years. This is a major program change that makes the Complete Ophthalmologic Care MVP mandatory for ophthalmologists participating in MIPS and not reporting the APM Performance Pathway. ASCRS maintains that the traditional MIPS pathway should continue to be an option and will continue to oppose this policy.
Complete Ophthalmologic Care MVP
CMS has finalized modifications to the Complete Ophthalmologic Care MVP to align with the measure changes and the addition of core measures to the Quality category.
Quality Measure Removals. CMS has finalized the removal of the following measures from the MVP:
- IRIS13: Diabetic Macular Edema - Loss of Visual Acuity
- Due to high average performance and little room for improvement.
- IRIS54: Complications After Cataract Surgery
- Due to high average performance and little room for improvement.
- 384: Adult Primary Rhegmatogenous Retinal Detachment Surgery: No Return to the OR within 90 Days of Surgery
- Finalized for removal from the MIPS program due to being topped out for 3 or more consecutive years.
Core Measures. For this MVP, clinicians not in a small practice will have to report on one of the following quality measures or attest to a lack of applicable core measures:
- Q012: Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation
- Q141: Primary Open-Angle Glaucoma (POAG): Reduction of Intraocular Pressure (IOP) by 20% OR Documentation of a Plan of Care
- Q304: Cataracts: Patient Satisfaction within 90 Days Following Cataract Surgery
- Q385: Adult Primary Rhegmatogenous Retinal Detachment Surgery: Visual Acuity Improvement Within 90 Days of Surgery
- Q501: Acute posterior vitreous detachment and acute vitreous hemorrhage appropriate examination and follow-up
Performance Threshold
CMS will maintain the current penalty avoidance threshold of 75 points for the 2026–2028 performance years to provide continuity and stability to MIPS clinicians.
Performance Category Weights
For the 2027 performance year/2029 payment year, the performance category weights are the following:
- 30% for the Quality performance category
- 30% for the Cost performance category
- 15% for the Improvement Activities performance category
- 25% for the Promoting Interoperability performance category
Quality
CMS will maintain a data completeness threshold of 75% for 2027 and 2028 performance periods.
Significant Changes to Reporting Requirements: Core Measures
CMS has finalized their proposal to create and implement core measure designations for quality measures in both traditional MIPS and in MVPs.
Previously, clinicians and groups were required to report at least one outcome/high priority measure. CMS has removed the high priority measure designation and, instead, require reporting at least one core measure beginning in performance year 2027.
In cases in which a clinician or group does not have a core measure available and applicable to their practice, CMS will require an attestation to this effect during submission. CMS also finalized their proposal to exempt clinicians in small practices from the MIPS core measure requirement and the attestation process.
Defined Topped Out Measure Benchmarks
Core measures will not be subject to the 7-point cap. Instead, if a core measure is topped out for 2 or more years, it will be scored from 1 to 10 points using the defined benchmark.
Relevant Measures Finalized for Removal in 2027:
- 384: Adult Primary Rhegmatogenous Retinal Detachment Surgery: No Return to the OR within 90 Days of Surgery
- Rationale for Removal: Has been topped out for 3+ consecutive years.
Cost
There are no new MIPS Cost measures for performance year 2027, nor are there any major policy changes for the Cost category.
Promoting Interoperability
CMS has finalized several significant changes to the MIPS Promoting Interoperability (PI) category. The following changes will begin in performance year 2027, unless otherwise specified:
- For 2026 MIPS: CMS has removed the ONC Direct Review and ONC-Authorized Certification Bodies Surveillance attestations.
- Security Risk Analysis (SRA) attestation: CMS will remove this attestation beginning with the 2027 performance year.
- Electronic Prior Authorization measure:
- Optional 10-point bonus measure for the 2027 performance year
- Required measure beginning with the 2028 performance year
- Measure actions must be completed for at least one prior authorization request for at least one medical item or service (excluding drugs).
- 2027 Requirements: CMS will require the prior authorization(s) be completed using at least one specific FHIR-enabled ONC-certified health IT module within your CEHRT to get measure credit.
- 2028 Requirements: CMS will require the use of CEHRT that includes Health IT Modules certified to all three ONC electronic prior authorization criteria.
- New Electronic Prior Authorization for Prescription Drugs measure:
- Required beginning in 2028
- Requires the use of specific FHIR-enabled health IT modules within CEHRT to complete at least one prior authorization request for prescription drugs and medications.
Improvement Activities
CMS finalized the addition of 6 new improvement activities for the 2027 performance year:
- Use of Data to Improve Practice Workflows
- Understand and Improve Diagnostic Performance
- Systemic Screening and Intervention for Nutrition and other Health-Impacting, Non-Clinical Issues
- Advance Care Planning Conversations to Support Patient Wellness and Care Preferences
- Clinician Use of Artificial Intelligence to Improve Patient Care
- Lifestyle Approaches to Diabetes Remediation
CMS finalized the removal of 11 improvement activities for the 2027 performance year, including the following relevant improvement activities:
- IA_ CC_10: Care Transition Documentation Practice Improvements
- IA_ PSPA_2: Participation in MOC Part IV
Advanced Alternative Payment Model (A-APM) Qualifying Participants (QPs)
CMS has finalized its proposal to apply QP status at the TIN/NPI level, rather than the NPI level. Currently, the QP conversion factor update is applied to all services billed by the clinician (NPI), regardless of TIN. The finalized change, however, means that the QP conversion factor update will only be applied to codes billed under the APM’s TIN.
CMS will not apply this change to Partial QP status as it is not tied to the QP conversion factor. This means that both Partial QPs and QPs will still be able to elect not to participate in MIPS in any or all of the TINs they practice under.
A fact sheet is available on the finalized CY 2027 Quality Payment Program changes.
Additional Details to Come
ASCRS is reviewing the 2,468-page final rule, and additional information will be detailed in upcoming editions of Washington Watch Weekly.
ASCRS will continue to work with the medical community to fight harmful policies in the final rule.
