CMS comment deadline arrives for sweeping 2027 Medicare proposal

Public comments close September 14 on a sweeping Centers for Medicare & Medicaid Services proposal that could lower national physician-fee-schedule conversion factors and change rules for telehealth, remote monitoring, rural providers, accountable-care organizations and Medicare eligibility.

The proposal, identified as CMS-1848-P, is titled “Medicare and Medicaid Programs; CY 2027 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program.” It is a proposed rule, not a final Medicare payment or coverage decision.

What is happening September 14

CMS placed the 1,592-page proposal on public inspection July 14, 2026. It was scheduled for Federal Register publication July 16, and comments must be received by September 14, 2026.

Comments may be submitted electronically through the Regulations.gov docket for CMS-2026-2377, by regular mail or by express or overnight mail using the instructions in the proposed rule. CMS says commenters should identify file code CMS-1848-P and choose only one submission method.

The physician-payment headline

CMS projects a 2027 conversion factor of $33.17 for qualifying alternative-payment-model participants, a decrease of 40 cents, or 1.19%, from the current $33.57 factor. For other clinicians, CMS projects a conversion factor of $32.84, down 56 cents, or 1.68%, from the current $33.40 factor.

Those are national conversion-factor projections, not a blanket claim that every Medicare payment or clinician income will fall by the same percentage. Actual effects would vary by specialty, service mix, geography, practice costs and other proposed changes to relative-value units.

CMS attributes part of the year-over-year reduction to the expiration of a one-year 2.50% increase that applied in 2026 under Public Law 119-21. The proposal also includes statutory updates and proposed changes to work RVUs, which affect the final payment calculation.

Changes to care delivery and billing

CMS proposes to change how separately identifiable office or outpatient evaluation-and-management visits are paid when furnished on the same day as certain 0-, 10- or 90-day global procedures. If finalized, the most expensive service would be paid at 100% and the other services at 50%.

The proposal would also replace the separate G2211 add-on code with a modifier that increases the associated evaluation-and-management payment by 16%. CMS says the percentage approach would apply more evenly across visit levels.

A separate proposed modifier would be available to certain practitioners participating in a Medicare Shared Savings Program accountable-care organization or the Long-term Enhanced ACO Design Model. If finalized, that modifier would increase the associated evaluation-and-management payment by 32% to recognize additional resources tied to longitudinal care, total-cost accountability and quality reporting.

Remote-monitoring rules could also change. CMS proposes requiring remote therapeutic monitoring to be furnished only to established patients. For both remote patient monitoring and remote therapeutic monitoring, the proposal would require a separately reportable initiating visit when services begin. That visit would need to assess whether monitoring is clinically appropriate and could be furnished in person or through telehealth, subject to the proposed conditions.

CMS also proposes limiting payment for remote-monitoring services to clinical staff under the required supervision of, and employed by, the billing practitioner or practice rather than allowing the services to be outsourced in the manner described in the proposal. These are proposed conditions and differ from current policy.

For rural health clinics and federally qualified health centers, CMS proposes conforming regulatory changes related to 2026 legislation. The proposal would reflect extensions of certain telehealth authorities and would keep specified mental-health in-person requirements in abeyance through December 31, 2027. These provisions would not take effect unless finalized.

Drug rebates, ACOs and the eligibility section

The proposal covers more than physician payments. It includes Medicare prescription-drug inflation-rebate mechanics, including a proposed requirement that certain 340B-covered entities submit Part D claims data to a CMS repository beginning in 2027. It also proposes changes to the Medicare Shared Savings Program, quality reporting, ambulance payments and clinical laboratory fee-schedule rules.

A separate section would implement statutory limits on Medicare eligibility for certain individuals. CMS lists four categories: U.S. citizens or nationals; lawful permanent residents; Cuban and Haitian entrants; and people who lawfully reside in the United States under a Compact of Free Association.

If finalized, the proposal would establish termination notices, appeal rights and a special enrollment pathway for some people whose citizenship, nationality or immigration status changes. CMS’s Office of the Actuary estimates that approximately 32,000 individuals could lose Medicare coverage beginning in 2027. That number is an agency estimate used in the proposed rule; it is not a final coverage determination or an independent forecast.

What comes next

CMS must review the comments before issuing a final rule. Until that happens, the proposed conversion factors, billing changes, telehealth requirements, rural-provider provisions and eligibility procedures do not change Medicare policy.

CMS-1848-P also includes proposed changes to the Ambulatory Specialty Model, including provisions involving heart-failure and low-back-pain cohorts and a proposed January 1, 2027, start for affected performance periods. Those provisions, like the rest of the document, remain subject to the rulemaking process.

Sources

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