CMS Releases CY 2027 Medicare Physician Fee Schedule Proposed Rule: Proposed changes to Reimbursement, Coding, and Policies

On July 14, the Centers for Medicare & Medicaid Services (CMS) released the CY 2027 Medicare Physician Fee Schedule (MPFS) proposed rule and fact sheet. The rule proposes payment rates and policies for the coming year. SGO will be submitting comments prior to the September 14 deadline. 

Takeaways:

• Reimbursement for physician fee schedule services are projected to decrease because of the expiration of the 2.5% increase to the conversion factor Congress provided for 2026.
• CMS proposes to accept and pay for the new unbundled maternity code family, which includes new code 59XX9 (Subtotal or total hysterectomy after cesarean delivery). 
• The agency continues to seek feedback on a variety of topics ranging from preventive care to potential alternatives to the American Medical Association’s Current Procedural Technology (CPT) process.

Conversion Factor:

If finalized, SGO members should expect to see a decrease in Part B reimbursement as the 2.5% increase to the conversion factor Congress provided for 2026 expires on December 31. For the second year, there are two separate conversion factors: one for providers participating in qualifying advanced APMs, and the other for those who are not:

• Qualifying APM Conversion Factor: $33.17, a decrease of 1.19%
• Non-qualifying APM Conversion Factor: $32.84, a decrease of 1.68%

Despite these decreases, CMS estimates that oncology services delivered in the facility setting are expected to increase by 1% and those in the office setting are expected to remain the same; obstetrics and gynecology services are estimated to decrease by 2% in the facility setting and 1% in the office setting.

Other Provisions of Note:

• New Code for Subtotal or Total Hysterectomy After Cesarean Delivery: CPT code 59XX9 (Subtotal or total hysterectomy after cesarean delivery) becomes effective January 1, 2027. CMS proposes to accept the RUC recommended work relative value unit (RVU) of 15.56.
• Proposed Changes to the Global Periods: CMS proposes reducing payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished on the same day as a procedure included in a 0-, 10-, or 90-day global period by the same physician or another physician in the same practice. The most expensive service (either procedure or E/M visit) would be paid at 100%, while any additional same-day procedure(s) or E/M visit(s) would be paid at 50%. This policy will affect physicians who provide an E/M service, coupled with a same-day procedure.
• Deletion of HCPCS code G2211: CMS proposes to delete G2211 (Visit complexity inherent to evaluation and management associated with medical care services) and create a modifier to take its place. The modifier, MOD1, will have the exact same descriptor as G2211, and should be reported and billed in the same way as the G-code. The modifier, when appended to an appropriate E/M code, will be reimbursed at 16% of the value of the billed E/M code.

Requests for Information:

• CMS Seeks Comment on CPT: The agency is seeking comment on the federal government’s reliance on the use of CPT coding system and the AMA/RUC processes used to develop and value physician services. CMS specifically calls out its concerns regarding potential conflicts of interest in physician service valuation and requests feedback on alternative approaches including potential ICD-10-PCS- and DRG-like approaches to grouping and paying for services.
• Physician-Patient Clinical Trial Discussions: CMS is seeking comments on the potential development of a HCPCS G code to reimburse physicians or other qualified healthcare professionals who spend a minimum of 20 minutes counseling patients on clinical trial eligibility, options, risks, and benefits.  CMS noted that the current E/M CPT code family does not adequately capture the time, effort, work, and resources associated with physician/patient conversations regarding participation in clinical trials. The agency further acknowledged that the primary barrier to these discussions is the time and administrative burden on physicians, which are not currently recognized as specific elements within existing E/M coding.

CMS is accepting comments on the proposed rule through September 14, 2026, and is expected to release the final CY 2027 MPFS rule later this fall. SGO will continue to keep members informed of significant developments and the potential impact of finalized policies on gynecologic oncology practice.