2027 MEDICARE PHYSICIAN FEE SCHEDULE (MPFS)
PROPOSED RULE RELEASED
Includes 2027 Quality Payment Program Proposals
Proposed 2027 Conversion Factor:
$33.17 for Qualifying Alternative Payment Model (APM) participants
$32.84 for Nonqualifying APM participants
This afternoon, CMS released the CY 2027 MPFS Proposed Rule. CMS also released a press release, a physician fee schedule fact sheet, and a shared savings program fact sheet. ASCRS will be submitting comments, which are due September 14, 2026.
2027 MPFS Conversion Factor
As required by the MACRA statute, there are two separate conversion factors: one for qualifying alternative payment model (APM) participants, 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 +0.53% 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 proposed CY27 qualifying APM conversion factor is $33.17, and the proposed CY27 non-qualifying conversion factor is $32.84.
For ophthalmology, the estimated CY27 combined impact on total allowed charges from all proposed changes is -3%.
The proposed CY27 Medicare payment for 66984 is $444.34, which represents a -4% reduction from 2026.
Please see the attached Impact on CY 2027 Payment for Selected Procedures table.
Stand-Alone E/M Visits and Global Periods
For CY27, CMS is proposing to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure. The most expensive service (either surgical or E/M visit) would be paid 100%, and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%.
E/M Visit Complexity Add-On Code (G2211)
The use of the E/M visit complexity code, G2211, was implemented in CY 2025. CMS is proposing two changes, which include transitioning G2211 to a modifier that can be appended to the associated E/M base code, which will result in a 16% increase in payment for the E/M code. In addition, CMS is proposing to recognize additional resource costs incurred by practitioners in ACOs when providing longitudinal care. This modifier would 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 would increase payment for the associated E/M visit by 32%.
Practice Expense Changes
CMS is proposing to reform the way PE RVUs are assigned to specific services by reducing reliance on specialty-specific practice expense per hour (PE/HR) data. CMS is proposing to phase out, over 2 years, part of the methodology that ensures the overall number of PE RVUs by specialty is consistent with the old PE/HR data - Indirect Practice Cost Index (IPCI). The IPCI would be replaced with a PE stabilizer adjustment.
In addition, CMS is seeking comment on whether the site of service payment differential between facility and non-facility is still appropriate.
Improving Global Surgery Payment Accuracy
For CY27, in a continued effort to improve global surgical service valuation and payment, CMS is proposing to pause the data collection required by MACRA, as the current data shows that postoperative visits are not occurring and the reporting requirements are an undue burden to providers. CMS is soliciting comments on expanding data collection, as well as additional data sources that could be considered.
Request for Information (RFI) on Current Procedural Terminology (CPT) and RUC
The proposed rule includes a request for information (RFI) examining the AMA’s CPT coding system, CPT licensing, the CPT code development process, and the RUC.
Quality Payment Program
MIPS Value Pathways (MVPs)
CMS is proposing to officially sunset traditional MIPS and make MVPs mandatory beginning with the 2029 performance year/2031 payment year.
Although CMS has floated using this timeline several times in the past, in response to major pushback, they have never before proposed the sunset of traditional MIPS. This is a major proposal that, if finalized, would make 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.
Complete Ophthalmologic Care MVP
CMS is proposing modifications to the Complete Ophthalmologic Care MVP to align with the proposed measure changes and the addition of core measures to the Quality category.
Quality Measure Removals. CMS is proposing to remove 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
- Proposed 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 Proposals
CMS has not proposed changes to the performance threshold. CMS previously finalized maintaining a 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 Requirement
In this proposed rule, CMS proposes to create and implement core measure designations for quality measures in both traditional MIPS and in MVPs.
Currently, clinicians and groups are required to report at least one outcome/high priority measure. CMS is proposing to remove the high priority measure designation and, instead, require reporting at least one core measure.
In cases in which a clinician or group does not have a core measure available and applicable to their practice, CMS would require an attestation to this effect during submission. CMS also proposes to exempt clinicians in small practices from the MIPS core measure requirement and the attestation process.
Defined Topped Out Measure Benchmarks
CMS is proposing core measures would not be subject to the 7-point cap. Instead, if a core measure is topped out for 2 or more years, it would be scored from 1 to 10 points using the defined benchmark.
Relevant Measures Proposed for Removal in 2027:
- 384: Adult Primary Rhegmatogenous Retinal Detachment Surgery: No Return to the OR within 90 Days of Surgery
- Rationale for Proposed Removal: Has been topped out for 3+ consecutive years.
Cost
There are no proposed new MIPS Cost measures for performance year 2027 nor are there any major proposals for the Cost category.
Promoting Interoperability
CMS is proposing several significant changes to the MIPS Promoting Interoperability (PI) category. The following changes would begin in performance year 2027, unless otherwise specified:
- For 2026 MIPS: CMS is proposing to remove the ONC Direct Review and ONC-Authorized Certification Bodies Surveillance attestations.
- Security Risk Analysis (SRA) attestation: CMS proposes to remove this attestation beginning with the 2027 performance year.
- Electronic Prior Authorization measure proposals:
- Make this an optional 10-point bonus measure for the 2027 performance year
- Make this a required measure beginning with the 2028 performance year
- 2027 Requirements: CMS proposes to require only one prior authorization using at least one specific FHIR-enabled ONC-certified health IT module within your CEHRT to get measure credit.
- 2028 Requirements: CMS proposes to 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
- Require 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 is proposing to add 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 is proposing to remove 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
A fact sheet is available on the CY 2027 Quality Payment Program proposed changes.
Additional Details to Come
ASCRS is reviewing the 1,592-page proposed rule, and additional information will be detailed in upcoming editions of Washington Watch Weekly.
