Key Takeaways
What you will learn in this article
- 1Proposed 2027 conversion factors: $32.84 for most clinicians (−1.68%) and $33.17 for qualifying APM participants (−1.19%). The main driver is the expiration of the one-year 2.5% increase Congress provided for 2026.
- 2The 2.5% “efficiency adjustment” to non-time-based services, finalized for 2026, stays in place. Physician groups are lobbying to repeal or delay it.
- 3G2211 would become a modifier that raises the associated E/M payment by 16% (32% for Shared Savings Program ACO and LEAD participants).
- 4A stand-alone E/M on the same day as a 0-, 10-, or 90-day global procedure would be paid at 50% — a significant change for procedural specialties.
- 5CMS proposes sunsetting traditional MIPS after the 2028 performance year, so reporting would run through MIPS Value Pathways from 2029. The 75-point threshold is unchanged for 2027.
- 6Everything here is proposed. The final rule usually arrives in early November, and Congress has a long record of changing the conversion factor at year end.
Every July, CMS publishes the next year’s proposed Medicare Physician Fee Schedule, and every November it finalizes it. The CY 2027 proposal, released July 14, 2026, closed for comments on September 14. It is a dense document — but for most independent practices, six changes matter, and one of them redraws the MIPS program for the rest of the decade.
The Conversion Factor: Down, Because a One-Year Bump Expires
| Clinician type | 2026 conversion factor | 2027 proposed | Change |
|---|---|---|---|
| Most clinicians (not qualifying APM participants) | $33.40 | $32.84 | −$0.56 (−1.68%) |
| Qualifying APM participants | $33.57 | $33.17 | −$0.40 (−1.19%) |
Source: CMS CY 2027 PFS proposed rule fact sheet (July 14, 2026). Proposed values; subject to the final rule.
Chart
What moves the 2027 conversion factor (non-qualifying clinicians)
| Expiration of the one-year 2026 increase (Public Law 119-21) | −2.50% |
|---|---|
| Statutory MACRA update | +0.25% |
| Adjustment for proposed work RVU changes | +0.53% |
Approximate components as described in CMS’s fact sheet and published summaries; they combine to roughly −1.68%. Qualifying APM participants receive a +0.75% statutory update instead of +0.25%.
Two caveats before you budget around these numbers. First, the conversion factor isn’t your rate — proposed RVU changes move individual codes anywhere from about −6.6% to +11.1%, so your real change depends on your code mix. Second, Congress has repeatedly changed the conversion factor at year end, often in the final weeks of December. Treat $32.84 as the baseline, not a forecast.
The Efficiency Adjustment Stays
For 2026, CMS finalized a 2.5% reduction to work RVUs and intraservice time for non-time-based services, on the theory that procedures get faster as clinicians gain experience. The adjustment is to be recalculated and reapplied every three years, and CMS isn’t proposing changes to it for 2027. Time-based services such as E/M visits, behavioral health, and care management aren’t affected; procedure-heavy practices feel it most. Surgical societies have called for repeal, and the Efficiency Adjustment Delay Act (H.R. 7520) is pending in Congress.
E/M and Care-Management Changes
G2211 becomes a percentage modifier
The visit complexity add-on code would be replaced by a modifier that increases the associated E/M payment by 16%, or 32% for Shared Savings Program ACO and LEAD Model participants. Practices that already use G2211 will need to update charge capture and claim edits.
Same-day E/M with a global procedure paid at 50%
When a stand-alone E/M visit is billed on the same day as a 0-, 10-, or 90-day global procedure, the lower-valued service would be paid at 50%. Procedural specialties that routinely bill both — with modifier 25 — should model this now.
Advance care planning split
Two new HCPCS codes for ACP furnished by clinical staff under direct supervision; CPT 99497 and 99498 would be limited to time personally spent by the billing practitioner.
Remote monitoring tightened
Proposals would require an initiating visit and limit remote therapeutic monitoring to established patients, and CMS sought comment on bundling RPM/RTM codes into four new G-codes.
Shared medical appointments
CMS proposes separate coding and payment for group visits, which currently have no specific HCPCS code.
The Big One: An End Date for Traditional MIPS
CMS proposes to sunset traditional MIPS after the 2028 performance period (the 2030 payment year). From 2029, clinicians would report through MIPS Value Pathways (MVPs) — specialty-focused bundles of quality measures, improvement activities, and cost measures — or through an APM. If finalized, most practices have two more performance years in the program they know.
2026 performance yearNow
Now
Traditional MIPS, MVPs, and APM reporting all available. Threshold 75 points.
2027 performance year
Three new MVPs proposed
Diabetic Disease, Hypertension, and Hospitalist. Every MVP would include MIPS “core” measures. Threshold stays at 75.
2028 performance year
Last year of traditional MIPS (proposed)
The final year to report outside an MVP or APM, under the proposal.
2029 performance year
MVP-only reporting (proposed)
Clinicians report through an MVP or an APM. Adjustments from 2029 performance land in 2031 payments.
Traditional MIPS today
Pick any six measures
- Choose six quality measures from the full inventory, including one outcome or high-priority measure
- Report the same measures whatever your specialty mix
- “High priority” designation helps satisfy requirements
MVP-only future (proposed)
A specialty-defined set
- Report a smaller measure set chosen from your specialty’s MVP — four quality measures in many MVPs
- Each MVP would include MIPS core measures
- “High priority” designation eliminated, replaced by a core measure list
- Multispecialty groups may need subgroups so each specialty reports its own MVP
For some specialties, the shift narrows options sharply. The diagnostic radiology MVP, for example, offers three quality measures — #405, #406, and the outcome measure #494 — compared with six in the traditional specialty set. For groups that already have little room to choose, every one of those measures will matter more.
Free tool · No signupMIPS Final Score EstimatorSee how your category weights and performance combine into a final score — and how far you are from 75.Estimate my scoreWhat to Do Before January
- 1Model your 2027 revenue by code, not by conversion factor: pull your top 30 CPT codes by Medicare volume and apply the proposed RVUs once the final rule publishes.
- 2If you bill E/M with procedures on the same day, quantify how often and what a 50% reduction on the lower-valued service would cost.
- 3Update G2211 workflows and claim edits for the modifier approach once the final rule confirms it.
- 4Review RPM/RTM enrollment workflows: initiating visits, established-patient status, and documentation.
- 5Start MVP planning now. Identify the MVP that fits each specialty in your group, and test-report through it in 2027 or 2028 while traditional MIPS is still a fallback.
- 6Watch the final rule in early November and any year-end congressional action on the conversion factor and efficiency adjustment.
What is the proposed 2027 Medicare conversion factor?+
$32.84 for most clinicians (a 1.68% decrease from $33.40) and $33.17 for qualifying APM participants (a 1.19% decrease from $33.57), per CMS’s July 2026 proposed rule.
Why is the conversion factor going down?+
Mainly because the one-year 2.5% increase Congress provided for 2026 expires. Small statutory updates and a budget-neutrality adjustment offset part of it.
Is traditional MIPS really ending?+
CMS has proposed sunsetting it after the 2028 performance year. It isn’t final until the rule is finalized, and it could change. But CMS has been moving toward MVPs for several years, so planning for the transition is sensible.
Did the MIPS performance threshold change for 2027?+
No. CMS proposes keeping it at 75 points, consistent with its plan to hold the threshold at 75 through the 2028 performance year.
When will the final 2027 fee schedule be published?+
CMS typically releases the final rule in early November, effective January 1. Congress can still change payment levels by legislation afterwards.
Does the efficiency adjustment affect E/M visits?+
No. It applies to non-time-based services. Time-based services such as E/M visits, behavioral health services, and care management are excluded.
Sources & References
- [1]CMS — Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule fact sheet
- [2]MGMA — Analysis: 2027 Medicare PFS proposed rule for medical practices
- [3]McDermott+ — CY 2027 PFS proposed rule takeaways
- [4]American College of Cardiology — CMS releases 2027 Medicare PFS proposed rule
- [5]MDinteractive — 2027 QPP proposed rule: what’s changing and why it matters
- [6]ReportingMD — CMS proposed an expiration date for traditional MIPS
- [7]American College of Surgeons — Comments on the CY 2027 PFS proposed rule (September 14, 2026)
