2027 MPFS Final Rule Highlights

Key Proposals That Survived the 2027 Final Rule Process

E/M and Procedure on Same Day 

• Highest procedure paid 100% then others at 80%
  • (20% reduction vs. proposed 50%)
• Applies to 0 global day procedures

Example: A dermatologist performs a lesion destruction (highest-valued service) and bills a separate, medically necessary E/M with modifier 25 on the same date. The procedure is paid at 100%, while the E/M is subject to the new reduction methodology, paid at 80%.

G2211 is becoming modifier B1

• Modifier increases E/M by 16% vs. flat fee assigned previously

Example: A family physician sees the same patient every few months to manage diabetes, hypertension, and medication adjustments over time. Because the visit represents ongoing, continuous care for the patient’s overall health needs, the E/M service qualifies for modifier B1. The eligible office visit with modifier B1 receives the enhanced 16% payment adjustment.

ACO participating providers – B2 modifier

• Modifier increases E/M by 32%
• Only available for practitioners participating in a Shared Savings Program ACO or Participant Providers in a Long-term Enhanced ACO Design (LEAD) Model ACO.

Example: A primary care physician participating in a Medicare Shared Savings Program ACO reports an eligible office visit with modifier B2 and receives the enhanced 32% payment adjustment.

Remote Monitoring

1. RTM services be furnished only to established patients;
2. Practitioners reporting RPM or RTM services must furnish a separately reportable initiating visit in association with the onset of RPM or RTM services;
3. Updates to how these services are valued under the PFS;
4. Only allowing payment for RPM or RTM services when performed by clinical staff employed by the practice and not when those services are delivered by contractors.
   1. This one won’t go into effect until January 1, 2029

Example: An established COPD patient completes an office visit before RTM services begin, and the monitoring services are subsequently provided by clinical staff employed by the practice rather than a third-party contractor.

Payment for the Diagnosis and Treatment of Vaccine Adverse Effects 

• We are finalizing add-on coding and payment for activities that are above and beyond those captured in an E/M visit for the diagnosis and treatment of vaccine adverse effects.
• These services entail listening to patient concerns, answering questions, and building trust. Also, selecting diagnosis strategies and conveying information in a manner specific to each patient’s concerns, personal beliefs, and literacy level.  This includes planning resources for treatment of symptoms of vaccine adverse effects.

Example: A physician evaluates a patient experiencing prolonged symptoms following a vaccine, spends additional time addressing concerns, discussing treatment options, and providing education, then reports the E/M service plus the new add-on code.

Advanced Care Planning

Two new G-codes for clinical staff work in Advanced Care Planning:

• (HCPCS codes G0572 and G0573)
• Two existing codes may only be reported for time personally spent by billing provider – ACP
  • (CPT codes 99497 and 99498)

Example: A nurse conducts 30 minutes of ACP activities under physician supervision, allowing reporting of the new ACP clinical staff G-code. CPT 99497 remains reserved for physician or qualified practitioner time personally spent.

Limiting Medicare Coverage of Certain Individuals

CMS is changing Medicare eligibility rules so that only certain immigration and citizenship categories can qualify for Medicare.

Eligibility is limited to these four groups:

1. U.S. citizens or U.S. nationals
2. Lawful permanent residents (green card holders)
3. People with Cuban or Haitian entrant status
4. People who legally reside in the U.S. under a Compact of Free Association (primarily certain citizens of the Marshall Islands, Micronesia, and Palau)

CMS is implementing the WFTC legislation by finalizing amendments to current Medicare regulations to incorporate the newly specified groups of individuals who may be eligible (as noted above) for Medicare.  Procedures for termination and applicable appeal rights are available for those found ineligible, and enrollment options for individuals who later gain or regain eligibility.

Example: During a Medicare enrollment review, CMS determines an individual no longer meets one of the specified eligibility categories and applies the new termination and appeal processes established under the final rule.

Shared Medical Appointments

• Currently, no HCPCS code specifically describes shared medical appointments.
• For CY 2027, CMS is finalizing the proposal to establish separate coding and payment for shared medical appointments. Additionally, CMS is creating an add-on code to account for additional time for the service.

Example: An endocrinologist conducts a diabetes shared medical appointment for multiple patients, reporting the new stand-alone SMA code and add-on code for additional qualifying time.

Psychiatric Collaborative Care Model (CoCM) 

• Existing HCPCS Codes will be replaced with 2027 New CPT Codes
• RVUs will be expanded

Example: A primary care physician, behavioral health care manager, and psychiatric consultant coordinate treatment for a patient with depression and report the new 2027 CPT CoCM codes instead of the current HCPCS codes.

Global Surgery Payment Accuracy 

• Pausing data collection for 2027
• CMS currently has several years of data showing that the post-operative visits during the global period are not occurring, yet providers are still being paid for these visits under the current global payment policy.

Example: An orthopedic surgeon performs a procedure with a 90-day global period, but several expected postoperative visits are never furnished, illustrating CMS’s concern that existing global payments may overvalue post-op care.

Final Thoughts

The 2027 MPFS Final Rule brings more than payment updates. From modifier B1 to remote monitoring and shared medical appointments, these changes will require education, workflow adjustments, and documentation readiness. Early preparation can reduce compliance risk and support accurate reimbursement.

Resources

2027 CMS MPFS Proposed Rule | McGovern Medical School

Federal Register – CY2027 Final Rule (MPFS) (external link)