OmniMD Responds to CY2027 Medicare Physician Fee Schedule: Practices Must Turn Payment Changes Into Revenue Workflows

Lower conversion factors, a G2211 modifier and a proposed 50% cut to same-day E/M pay mean practices should update coding and billing before January 1, 2027

HAWTHORNE, NY, UNITED STATES, October 8, 2026 /EINPresswire.com/ — A lower conversion factor, a redesigned G2211 and a proposed cut to same-day E/M visits mean practices that update coding and billing workflows before January 1 can protect revenue the rule would otherwise take

OmniMD, a provider of EHR, practice management and revenue cycle technology for independent and specialty practices, today released its analysis of the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P). OmniMD urges practices to start planning for the rule’s operational changes before the final rule arrives.

CMS released the proposed rule on July 14, and it was published in the Federal Register on July 16, 2026. Comments were accepted through September 14. The final rule is expected around November 1, 2026, and takes effect January 1, 2027.

𝐓𝐡𝐞 𝐂𝐨𝐧𝐯𝐞𝐫𝐬𝐢𝐨𝐧 𝐅𝐚𝐜𝐭𝐨𝐫 𝐃𝐫𝐨𝐩𝐬 𝐟𝐨𝐫 𝐄𝐯𝐞𝐫𝐲 𝐏𝐫𝐚𝐜𝐭𝐢𝐜𝐞

• 𝐓𝐰𝐨 𝐥𝐨𝐰𝐞𝐫 𝐜𝐨𝐧𝐯𝐞𝐫𝐬𝐢𝐨𝐧 𝐟𝐚𝐜𝐭𝐨𝐫𝐬: The proposed qualifying APM conversion factor of $33.17 is a $0.40 (1.19%) decrease from $33.57. The nonqualifying factor of $32.84 is a $0.56 (1.68%) decrease from $33.40.

• 𝐖𝐡𝐲 𝐫𝐚𝐭𝐞𝐬 𝐟𝐚𝐥𝐥: The cut stems largely from the expiration of a temporary 2.50% increase Congress attached to CY 2026 payments. Statutory updates of 0.75% for qualifying APM participants and 0.25% for others, plus an estimated 0.53% adjustment tied to changes in work RVUs, only partly offset the loss.

• 𝐄𝐟𝐟𝐢𝐜𝐢𝐞𝐧𝐜𝐲 𝐚𝐝𝐣𝐮𝐬𝐭𝐦𝐞𝐧𝐭 𝐬𝐭𝐚𝐲𝐬: The minus 2.5% efficiency adjustment introduced in the 2026 final rule remains in effect under this proposal.

• 𝐂𝐨𝐬𝐭𝐬 𝐤𝐞𝐞𝐩 𝐫𝐢𝐬𝐢𝐧𝐠: CMS projects practice costs will increase another 2.5% in 2027. According to AMA analysis, Medicare physician pay declined 33% between 2001 and 2025 after adjusting for inflation in practice costs.

𝐓𝐡𝐫𝐞𝐞 𝐏𝐨𝐥𝐢𝐜𝐲 𝐂𝐡𝐚𝐧𝐠𝐞𝐬 𝐖𝐢𝐥𝐥 𝐒𝐡𝐚𝐩𝐞 𝐑𝐞𝐯𝐞𝐧𝐮𝐞 𝐌𝐨𝐬𝐭

The conversion factor sets the baseline. However, three policies decide whether a given practice ends 2027 ahead or behind.

𝐒𝐚𝐦𝐞-𝐝𝐚𝐲 𝐄/𝐌 𝐯𝐢𝐬𝐢𝐭𝐬 𝐰𝐢𝐭𝐡 𝐩𝐫𝐨𝐜𝐞𝐝𝐮𝐫𝐞𝐬 (𝐦𝐨𝐝𝐢𝐟𝐢𝐞𝐫 𝟐𝟓)

• When an E/M visit is performed on the same day as a procedure with a 0-, 10- or 90-day global period, the higher-valued service would be paid in full. Additional same-day services would be paid at 50%.
• The reduction applies when the E/M is provided by the same physician or another physician in the same group.
• The American Academy of Otolaryngology–Head and Neck Surgery urged CMS not to finalize the cut, citing data from more than 1,400 members on threats to patient access and practice viability.

𝐆𝟐𝟐𝟏𝟏 𝐛𝐞𝐜𝐨𝐦𝐞𝐬 𝐚 𝐦𝐨𝐝𝐢𝐟𝐢𝐞𝐫

• The modifier would be billed in the same circumstances as G2211 today, valued at 16% of the base E/M code.
• A separate modifier for practitioners in Shared Savings Program or LEAD Model ACOs would be valued at 32% of the base E/M code.

𝐏𝐫𝐚𝐜𝐭𝐢𝐜𝐞 𝐞𝐱𝐩𝐞𝐧𝐬𝐞 𝐦𝐞𝐭𝐡𝐨𝐝𝐨𝐥𝐨𝐠𝐲

• CMS would phase out the Indirect Practice Cost Index (IPCI), which allocates overhead such as rent and administrative staff. It would apply 50% of the IPCI adjustment in 2027 and eliminate it entirely in 2028.
• The IPCI is based on the AMA’s 2007 Physician Practice Information Survey. A new PE stabilizer would cap most codes’ annual PE changes at ±5%.
• MedPAC supports eliminating the IPCI and the new PE stabilization adjustment.

𝐒𝐩𝐞𝐜𝐢𝐚𝐥𝐭𝐲 𝐈𝐦𝐩𝐚𝐜𝐭 𝐕𝐚𝐫𝐢𝐞𝐬 𝐖𝐢𝐝𝐞𝐥𝐲

• 𝐎𝐩𝐡𝐭𝐡𝐚𝐥𝐦𝐨𝐥𝐨𝐠𝐲: The estimated combined impact on total allowed charges is -3%.
• 𝐎𝐁/𝐆𝐘𝐍 𝐚𝐧𝐝 𝐠𝐲𝐧𝐞𝐜𝐨𝐥𝐨𝐠𝐢𝐜 𝐨𝐧𝐜𝐨𝐥𝐨𝐠𝐲: OB/GYN services are estimated to fall 2% in facilities and 1% in offices. Gynecologic oncology rises 1% in facilities and holds steady in offices.

𝐐𝐮𝐚𝐥𝐢𝐭𝐲 𝐑𝐞𝐩𝐨𝐫𝐭𝐢𝐧𝐠, 𝐓𝐞𝐥𝐞𝐡𝐞𝐚𝐥𝐭𝐡 𝐚𝐧𝐝 𝐍𝐞𝐰 𝐌𝐨𝐝𝐞𝐥𝐬

• 𝐌𝐈𝐏𝐒 𝐞𝐧𝐝𝐬 𝐚𝐟𝐭𝐞𝐫 𝟐𝟎𝟐𝟖: Traditional MIPS would sunset after CY 2028, leaving MVPs as the only option outside the APM Performance Pathway from CY 2029.
• 𝐐𝐮𝐚𝐥𝐢𝐭𝐲 𝐦𝐞𝐚𝐬𝐮𝐫𝐞𝐬: CMS proposes core measure designations for quality measures and has not proposed changes to the performance threshold.
• 𝐂𝐞𝐫𝐭𝐢𝐟𝐢𝐞𝐝 𝐄𝐇𝐑 𝐝𝐞𝐟𝐢𝐧𝐢𝐭𝐢𝐨𝐧: The MIPS CEHRT definition would be updated to align with ONC’s HTI-5 proposed rule starting with the 2027 performance year.
• 𝐓𝐞𝐥𝐞𝐡𝐞𝐚𝐥𝐭𝐡: The Consolidated Appropriations Act, 2026 extended Medicare telehealth flexibilities through December 31, 2027. The rule would raise the originating site fee (Q3014) from $31.85 to $32.65.
• 𝐀𝐦𝐛𝐮𝐥𝐚𝐭𝐨𝐫𝐲 𝐒𝐩𝐞𝐜𝐢𝐚𝐥𝐭𝐲 𝐌𝐨𝐝𝐞𝐥: The rule includes proposed changes to the mandatory Ambulatory Specialty Model, which begins January 1, 2027.

𝐓𝐮𝐫𝐧𝐢𝐧𝐠 𝐏𝐚𝐲𝐦𝐞𝐧𝐭 𝐂𝐡𝐚𝐧𝐠𝐞𝐬 𝐈𝐧𝐭𝐨 𝐑𝐞𝐯𝐞𝐧𝐮𝐞 𝐖𝐨𝐫𝐤𝐟𝐥𝐨𝐰𝐬

OmniMD recommends that practices act on the proposal now and confirm details once the final rule is published.

• 𝐑𝐞-𝐦𝐨𝐝𝐞𝐥 𝟐𝟎𝟐𝟕 𝐫𝐞𝐯𝐞𝐧𝐮𝐞 𝐛𝐲 𝐂𝐏𝐓 𝐟𝐚𝐦𝐢𝐥𝐲: Run your top Medicare codes against the proposed conversion factor and your specialty’s estimated impact.
• 𝐀𝐮𝐝𝐢𝐭 𝐬𝐚𝐦𝐞-𝐝𝐚𝐲 𝐄/𝐌 𝐚𝐧𝐝 𝐩𝐫𝐨𝐜𝐞𝐝𝐮𝐫𝐞 𝐩𝐚𝐢𝐫𝐬: Find how often visits coincide with global procedures, and make sure documentation clearly separates the two services.
• 𝐁𝐮𝐢𝐥𝐝 𝐭𝐡𝐞 𝐆𝟐𝟐𝟏𝟏 𝐦𝐨𝐝𝐢𝐟𝐢𝐞𝐫 𝐢𝐧𝐭𝐨 𝐯𝐢𝐬𝐢𝐭 𝐭𝐞𝐦𝐩𝐥𝐚𝐭𝐞𝐬: Prompt clinicians when a visit meets longitudinal care criteria, and update charge capture so the modifier replaces the retired code.
• 𝐑𝐞𝐯𝐢𝐞𝐰 𝐀𝐏𝐌 𝐚𝐧𝐝 𝐀𝐂𝐎 𝐬𝐭𝐚𝐭𝐮𝐬: The gap between conversion factors and the 32% versus 16% modifier values make participation decisions more financially material.
• 𝐏𝐥𝐚𝐧 𝐭𝐡𝐞 𝐌𝐕𝐏 𝐭𝐫𝐚𝐧𝐬𝐢𝐭𝐢𝐨𝐧: Choose a pathway that fits your specialty during 2027 and 2028.
Check commercial contracts: Payer contracts priced as a percentage of Medicare will move with the conversion factor.

“The 2027 fee schedule pays practices for how well their workflows match the rule,” said Divan Dave, CEO, OmniMD. “A visit that qualifies for the new G2211 modifier but goes out without it is lost revenue. So is a same-day E/M paid at half because the documentation didn’t separate it from the procedure. Practices that update templates, charge capture rules and coding audits before January will keep revenue that others only discover missing in their first-quarter remittances.”

Divan added, “Every one of these policies can still change in the final rule. That is why we are helping practices build workflows they can adjust quickly, rather than locking in assumptions that may not survive November.”

𝐀𝐛𝐨𝐮𝐭 𝐎𝐦𝐧𝐢𝐌𝐃
OmniMD is a healthcare technology company founded in 2002 and headquartered in Hawthorne, New York. The company provides electronic health records, practice management, revenue cycle management, patient engagement, telemedicine, and interoperability solutions to medical practices across the United States. OmniMD’s platform serves more than 12,000 medical professionals across more than 20 clinical specialties. More information is available at omnimd.com.

Divan Dave
OmniMD
844-666-4631
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