Physician practices face a crowded 2027: a proposed Medicare pay cut, a mandatory specialty model, the end of MIPS and new rules for remote monitoring and same-day visits. Most of the changes come from CMS’ proposed 2027 physician fee schedule, released July 14. CMS is expected to finalize it in November.
The Medical Group Management Association’s government affairs team outlined the policies it is tracking in a briefing reported by Medical Economics. Congress could still change several Medicare provisions before federal funding runs out Dec. 11.
Here are the 10:
1. Another Medicare pay cut
Status: Proposed. The conversion factor for most physicians would fall 1.68% to $32.84. Qualifying alternative payment model participants would see a 1.19% drop to $33.17. The cut follows the expiration of a one-year 2.5% increase for 2026.
2. A 50% cut for same-day services
Status: Proposed. When an evaluation and management visit billed with modifier 25 falls on the same day as a 0-, 10- or 90-day global procedure, only the highest-valued service would be paid in full. The rest would be paid at 50%. The AMA and more than 150 groups asked CMS to drop it.
3. MIPS reaches its end
Status: Proposed. 2028 would be the last performance year for the traditional Merit-based Incentive Payment System. Clinicians outside an APM would report through MIPS Value Pathways starting in 2029.
4. Automatic downcoding in Medicare Advantage
Status: Draft bill, not introduced. MGMA is shopping a draft bill that would ban automatic downcoding in Medicare Advantage. A fallback would allow it only when a plan shows a physician upcodes above a set rate, for no more than 90 days, with notice to the physician.
5. Prior authorization comes to traditional Medicare
Status: In effect. CMS’ Wasteful and Inappropriate Service Reduction Model has used AI-assisted prior authorization review for select traditional Medicare services since Jan. 1 in Arizona, New Jersey, Ohio, Oklahoma, Texas and Washington. The six-year pilot targets services including epidural steroid injections, nerve stimulator implants and vertebral augmentation. The full spending bill has not passed, and a similar rider failed to make the final 2026 law.”
6. Medicaid work requirements begin
Status: Law, states must implement by Jan. 1, 2027. MGMA expects more administrative work and more uncompensated care as states roll out requirements. Caps on state-directed payments phase in from 2028.
7. Electronic prior authorization comes due
Status: Deadline, Jan. 1, 2027. Medicare Advantage and Medicaid plans must support electronic prior authorization by Jan. 1. The AMA has asked CMS to hold the date, saying physicians still lack details from plans and EHR developers on what will be ready.
8. G2211 becomes a modifier
Status: Proposed. CMS would replace the G2211 complexity add-on code with a modifier that raises payment for the E/M base code by 16%. A second modifier would raise it 32% for Medicare Shared Savings Program and LEAD Model clinicians.
9. A mandatory specialty model begins
Status: Mandatory model, starts Jan. 1, 2027. The Ambulatory Specialty Model pulls select specialists treating heart failure or low back pain into a mandatory payment model through 2031. CMS’ final participant list includes 5,533 clinicians, with no opt-out.
10. Remote monitoring goes in-house only
Status: Proposed. Medicare would pay for remote physiologic and therapeutic monitoring only when a practice’s own employed clinical staff provide it, cutting out third-party vendors. Practices would also need an initiating visit before billing, and many monitoring codes would be revalued. An HHS Office of Inspector General report found remote patient monitoring payments rose 31% to $536 million in 2024.
What Congress could still change
Federal funding runs out Dec. 11. Three temporary Medicare provisions expire at the end of 2026 unless Congress acts:
- The 1.0 work geographic practice cost index floor
- The advanced APM incentive payment
- The delay of clinical lab fee schedule cuts, which MGMA estimates would average about 16% and phase in over three years
MGMA is pushing for a year-end package to address all three. Telehealth flexibilities are already extended through Dec. 31, 2027.
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