The following is an update on the recently released CY 2027 Medicare Physician Fee Schedule Proposed Rule.
Important Takeaways
CY 2027 Medicare Physician Fee Schedule Proposed Rule
CMS has issued the Calendar Year (CY) 2027 Medicare Physician Fee Schedule proposed rule. The annually issued rule outlines proposed changes to Medicare payment rates, quality reporting programs, and more.
The proposed conversion factor applicable to the majority of physicians is $32.8409, which reflects a 1.68 percent reduction from CY 2026. As required by statute, a separate conversion factor of $33.1693 (which reflects 1.19 percent reduction from CY 2026) is proposed for Qualifying Alternative Payment Model Participants (QPs).
Same-Day E/M and Procedure Payment Reduction
CMS has proposed a significant change to physician payment beginning in CY 2027. Under the proposal, when a separately identifiable office/outpatient evaluation and management (E/M) visit is provided on the same day as a procedure with a 0-, 10-, or 90-day global period by the same physician (or another physician in the same practice), Medicare would pay 100 percent for the highest-valued service and only 50 percent for all other eligible procedures or E/M services performed that day.
APMA strongly opposes this proposal, which would reduce reimbursement for medically necessary, separately identifiable services that require distinct clinical judgment and are appropriately reported under existing Medicare billing rules. APMA will work closely with other physician organizations and stakeholders to vigorously oppose this policy and advocate for preserving appropriate reimbursement for the comprehensive care podiatric physicians provide to their patients.
Proposals for Skin Substitutes
CMS does not propose any changes to payment for sheet form skin substitutes for CY 2027, meaning that skin substitutes will continue to be treated as separately payable incident to supplies when furnished in the physician office. For most skin substitute products, CMS has assigned 3.87 PE RVU for CY 2027, which translates to $127.09 when applying the non-QP conversion factor.
For non-sheet form skin substitutes, CMS proposes to nationally price products at the same per-square-centimeter (cm²) rate as sheet-form products for CY 2027, which departs from its contractor pricing policy for CY 2026. CMS believes the resource costs for non-sheet and sheet-form skin substitutes are comparable. For non-sheet products, CMS also clarifies that the reported cm² reflects the wound surface area treated—not the physical size of the product.
RVU Win
CMS has proposed to adopt the AMA RUC-recommended RVUs and direct practice expense (PE) inputs for skin cell suspension autograft services exactly as recommended. APMA, as the only podiatric representative on the AMA Relative Value Scale Update Committee (RUC), played a key role in developing these recommendations and is pleased that CMS accepted them without modification.
Merit-based Incentive Payment System (MIPS)
CMS is proposing to phase out traditional MIPS reporting after the CY 2028 performance period. Beginning with the CY 2029 performance period, MIPS Value Pathways (MVPs) would become the only MIPS reporting option for eligible clinicians who are not participating in a MIPS Alternative Payment Model (APM). This proposal follows CMS's finalization of the Podiatry MVP in last year's rule, creating a specialty-specific reporting pathway tailored to podiatric physicians. CMS is also proposing to expand the MVP portfolio by adding a new Diabetic Disease MVP.
Other proposals that APMA is currently evaluating include:
Overall, APMA estimates that the proposed rule would result in an average 6 percent decrease in Medicare reimbursement for podiatric physician services in non-facility settings, while facility-based podiatry services are estimated to have a 2 percent decrease. Actual impacts will vary depending on a practice's patient mix, service mix, coding patterns, and geographic location. APMA will vigorously oppose these proposed cuts and advocate to protect reimbursement for podiatric physicians and preserve patient access to high-quality foot and ankle care.
Additional information is included in the links below:
Medicare Physician Payment Reform Bill Introduced
This week, Representatives John Joyce, MD (R-PA), Kim Schrier, MD (D-WA), and Greg Murphy, MD (R-NC) introduced the bipartisan Patients First Act, an important step toward modernizing the Medicare physician payment system and strengthening access to physician-led care. Physicians, including podiatrists, have faced years of inadequate Medicare payment updates that have failed to keep pace with rising practice costs, placing increasing strain on independent practices and threatening patient access to care.
As CMS proposes yet another round of Medicare physician payment cuts, APMA applauds physician leaders in Congress for advancing a bipartisan solution to stabilize reimbursement and protect patient access to care.
Podiatric physicians play a vital role in preventing lower extremity complications, preserving mobility, and improving the health and quality of millions of Medicare beneficiaries. A more stable, predictable physician payment system is essential in ensuring podiatric practices can continue providing timely, high-quality care in communities across the country.
APMA appreciates the bipartisan leadership of the GOP and Democratic Doctors Caucuses for proposing solutions to stabilize physician payment and protect access to care. APMA also appreciates the transparent and collaborative process undertaken by the bill sponsors and their staff in developing this legislation and is grateful for the opportunity to provide input throughout its development
The APMA looks forward to reviewing the legislation in greater detail and working with Congress to advance comprehensive Medicare physician payment reforms that recognize the value of physician care, reduce unnecessary administrative burdens, and ensure Medicare beneficiaries continue to have access to the specialized foot and ankle care they need and deserve.