CMS 2027 Physician Fee Schedule: what practices should watch

Start with the status of the rule

CMS issued the CY 2027 Physician Fee Schedule proposed rule on July 14, 2026. That matters because a proposed rule is not the operating manual yet. It is the version practices use for planning, comments, and finance scenarios while waiting for the final rule.

For practice leaders, the mistake is either ignoring it until January or treating every proposal as certain. The better path is to list the workflows that would be affected if the proposals survive: office E/M, same-day procedures, G2211, remote monitoring, chronic care, behavioral health, laboratory data, and ACO participation.

The payment pressure is real, even before the final rule

CMS describes two conversion factors for 2027: one for qualifying Advanced APM participants and one for non-qualifying clinicians. The proposed qualifying APM conversion factor is $33.17, down 1.19% from 2026. The proposed non-qualifying APM conversion factor is $32.84, down 1.68% from 2026.

That is not a coding detail. If the revenue per unit of work is pressured, the documentation supporting that work becomes more important. Practices need fewer missed conditions, fewer incomplete assessments, fewer unworked results, and fewer visits coded below the work actually performed.

The E/M and G2211 proposals deserve workflow review

CMS proposes reducing payment when a separately identifiable office or outpatient E/M visit is furnished by the same physician, or same group practice, on the same day as a procedure with a 0-, 10-, or 90-day global period. The highest-priced service would be paid at 100%, with other covered services paid at 50% under the proposal.

CMS also proposes changing G2211 from a separate add-on code into a modifier that would increase the associated E/M payment by 16%, with a separate ACO-related modifier at 32% for eligible participants if finalized. That makes front-end documentation, problem framing, and billing logic more tightly linked.

What to check before January

• Same-day E/M plus procedure encounters: how often they occur, who documents them, and whether medical necessity is clear.
• G2211 usage: which clinicians use it, for which conditions, and whether longitudinal complexity is stated in the assessment.
• Remote monitoring: whether the patient is established, whether the initiating visit is documented, and whether staff employment rules would affect the program if finalized.
• Chronic disease workflows: whether diabetes, hypertension, behavioral health, tobacco, and nutrition work is captured before the visit, not reconstructed afterward.
• Duplicate testing risk: whether outside labs and imaging reports reach the chart before clinicians reorder work that already exists.

Where Layrd fits

Layrd is useful here because these changes are not solved by a prettier note. They require the chart to be complete before the visit, with outside documents read, active conditions surfaced, prior results available, care gaps shown, and the draft assessment tied back to source documents.

When reimbursement rules get narrower, practices need less scavenger-hunt medicine. The physician should start with the record assembled, the likely coding and quality implications visible, and the source evidence one click away.

Sources

• CMS CY 2027 Medicare Physician Fee Schedule proposed rule fact sheet
• CMS CY 2027 PFS rulemaking page