The CMS 2027 physician fee schedule proposal could affect how medical practices bill E/M visits, procedures, global surgical services, G2211, quality reporting, and Medicare reimbursement. While some of the details are technical, the main takeaway is simple: practices should pay close attention to documentation, coding, billing workflows, and reporting changes before these policies are finalized.
These proposed updates may affect many specialties, including primary care, ophthalmology, orthopedics, dermatology, gastroenterology, rheumatology, cardiology, pain management, surgery, urology, podiatry, ENT, and other office-based specialties.
For practices that need help staying organized as billing and reimbursement rules change, Ameriton Workforce Solutions offers remote administrative support, billing support for medical practices, prior authorization support, and insurance verification support. You can also schedule a consultation with Ameriton Workforce Solutions to see how remote support can help your practice stay prepared.
CMS 2027 Physician Fee Schedule: E/M Visits With Procedures
One major issue CMS is asking about is when an evaluation and management visit should be paid separately from a procedure.
This matters because many procedures already include some pre-service and post-service work in their payment. Because of this, CMS wants more clarity on when the E/M work is already part of the procedure payment and when it is truly separate.
For example, if a patient comes in for a planned procedure, CMS may question whether a separate office visit should also be billed. However, if the provider evaluates a new problem, a new diagnosis, a different body part, or a separate medical concern, then a separately billable E/M visit may be appropriate.
Why This Matters for Medical Practices
This issue can affect many specialties that perform same-day procedures, including:
- Ophthalmology and retina
- Dermatology
- Orthopedics
- Pain management
- ENT
- Urology
- Gastroenterology
- General surgery
- Podiatry
- Cardiology
- Rheumatology practices with procedure or injection workflows
CMS is asking for input on how to tell the difference between routine procedure-related work and a significant, separately identifiable E/M visit.
In plain language, CMS wants to know: when is the visit really separate from the procedure?
CMS 2027 Physician Fee Schedule: Verifying Separate E/M Services
CMS is also asking how it can confirm that a billed E/M visit is significant and separately identifiable without needing to review the full medical record every time.
One possible idea is using different diagnosis codes to show that the E/M service was separate from the procedure. For example, if the procedure is tied to one diagnosis but the visit addresses a different condition, that may help support separate billing.
However, diagnosis codes alone may not always tell the full story. Practices should make sure documentation clearly explains why the E/M visit was separate, medically necessary, and not simply part of the procedure.
New Patients vs. Established Patients
The CMS 2027 physician fee schedule proposal also asks whether E/M work for new patients is usually included in minor procedure valuation or whether it should usually be paid separately.
This is important because new patients often require more work. A provider may need to review history, confirm a diagnosis, evaluate treatment options, discuss risks, and create a care plan before deciding whether a procedure is appropriate.
For established patients, the situation may be different. If the patient is returning for a planned procedure and nothing new is evaluated, CMS may view the E/M work as part of the procedure. However, if the patient has new symptoms, a new diagnosis, worsening findings, or a separate concern, the E/M service may be more clearly separate.
Documentation Matters More Than Ever
Because CMS is focusing on these questions, practices should make sure their documentation clearly supports E/M services billed with procedures.
A strong note should explain:
- Why the patient was evaluated
- What new or separate issue was addressed
- Whether the decision for the procedure was made that day
- Whether the visit involved a new diagnosis or worsening condition
- Whether the provider evaluated a separate problem
- Why the E/M service was significant and separately identifiable
- Why the visit was not simply routine procedure-related work
This does not mean practices should avoid billing legitimate E/M services. Instead, it means the documentation should clearly support what was done.
CMS 2027 Physician Fee Schedule Conversion Factor
CMS is proposing a 2027 conversion factor of $32.84 for physicians who do not participate in an advanced alternative payment model.
For physicians participating in advanced APMs, CMS is proposing a conversion factor of $33.1693.
This reflects a reduction from the 2026 conversion factor of $33.40.
For medical practices, the conversion factor matters because it helps determine Medicare payment rates. Even small changes can affect revenue, especially for practices with a large Medicare patient population.
Specialty Practices May Continue to Feel Reimbursement Pressure
CMS continues to focus on shifting reimbursement toward primary care and certain office-based services. As a result, many specialty and surgical groups have raised concerns that these changes can reduce reimbursement for procedural and surgical care.
CMS did not reverse certain policies that contributed to surgical reimbursement reductions in 2026. These include the efficiency adjustment and indirect practice expense methodology.
For specialties that rely heavily on procedures, surgeries, imaging, injections, or other technical services, this is important. Practices should review how proposed payment changes may affect revenue.
Global Surgical Data Collection Changes
CMS is proposing to suspend the ongoing required reporting of post-operative visits in certain states for certain procedures.
CMS is also asking for comments on other ways to value global period codes more accurately.
Global period codes affect many procedural and surgical specialties. These codes include payment for certain post-operative care within a defined period after a procedure.
Because of this, practices that perform surgeries or procedures should watch this closely. Changes to global period valuation can affect future reimbursement.
CMS 2027 Physician Fee Schedule and G2211
CMS previously finalized separate payment for HCPCS code G2211, the office and outpatient E/M visit complexity add-on code. Implementation was delayed by law, but it was implemented for 2025.
Now CMS is proposing to transition G2211 from a separate add-on code to a modifier that would be appended to the related E/M base code.
Instead of paying a flat amount, the modifier would increase payment for the associated E/M code by 16%.
This would create an equal percentage increase across E/M levels.
What G2211 Means in Simple Terms
G2211 is meant to recognize the added complexity of ongoing patient care relationships.
This may apply when a provider manages a patient’s long-term condition, coordinates care, or serves as the continuing focal point for care.
If CMS finalizes the modifier approach, practices will need to understand:
- When the modifier can be used
- Which E/M services qualify
- What documentation supports it
- How billing software should be updated
- Whether payer policies follow CMS’s approach
This could affect many specialties, not just primary care.
CMS 2027 Physician Fee Schedule and Quality Reporting
CMS is also proposing major changes to the Quality Payment Program.
After several years of rolling out MIPS Value Pathways, CMS is proposing to phase out traditional MIPS beginning in 2029.
That means eligible clinicians would eventually be required to report through an MVP instead of traditional MIPS.
CMS is also proposing that all MIPS-eligible clinicians report a specialty-relevant or patient-population-relevant “core” measure beginning in 2027. This would replace the current requirement to report an outcome or high-priority measure.
Why Quality Reporting Changes Matter
Quality reporting affects payment adjustments, compliance planning, and reporting workflows.
If traditional MIPS is phased out, practices will need to prepare for MVP reporting. This may require changes in:
- Measure selection
- EMR reporting
- Staff training
- Data capture
- Documentation workflows
- Vendor support
- Quality reporting strategy
Specialty practices should pay attention to which MVP applies to their specialty and what core measures CMS may require.
How Medical Practices Should Prepare for the CMS 2027 Physician Fee Schedule
Medical practices should not wait until 2027 to prepare.
Here are practical steps practices can take now:
- Review E/M billing with procedures
- Make sure documentation supports separate E/M services
- Review diagnosis coding patterns
- Train providers on significant and separately identifiable documentation
- Review same-day E/M and procedure workflows
- Monitor conversion factor changes
- Review specialty-specific payment impact
- Watch global period code developments
- Prepare billing systems for possible G2211 modifier changes
- Review MIPS or MVP reporting readiness
- Make sure staff understand payer and CMS requirements
- Run reports on E/M services billed with procedures
- Review denials related to modifiers, medical necessity, and documentation
Why Back-Office Support Matters
The CMS 2027 physician fee schedule proposal shows why medical practices need strong back-office systems.
Billing, coding, documentation, authorizations, reporting, and compliance are all connected. When rules change, practices need staff who can track updates, update workflows, review claims, and make sure documentation supports the services billed.
Remote administrative support can help practices stay organized by assisting with:
- Eligibility checks
- Prior authorization follow-up
- Claim status checks
- Denial tracking
- Documentation follow-up
- Report preparation
- AR support
- Quality reporting support
- Billing workflow organization
- Patient communication
- EMR task updates
As CMS rules continue to change, practices need clear workflows and reliable support.
Learn more about Ameriton’s remote administrative support, billing support for medical practices, prior authorization support, and insurance verification support.
The Bottom Line
The CMS 2027 physician fee schedule proposal could affect how medical practices bill E/M services, procedures, global period codes, G2211, quality reporting, and Medicare reimbursement.
The most important takeaway is that practices should focus on documentation, workflow, reporting, and billing accuracy.
If a service is separately billable, the medical record should clearly show why. If a procedure includes certain work, the practice should understand what is already included. Also, if quality reporting requirements change, practices should prepare early.
Medical practices that stay proactive will be in a better position to protect revenue, reduce denials, and adapt to future CMS payment changes.
Ameriton Workforce Solutions helps medical practices strengthen back-office workflows with trained remote support for eligibility, authorizations, billing follow-up, denials, reporting, and administrative tasks.
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