The Centers for Medicare and Medicaid Services (CMS) released the proposed Physician Fee Schedule (PFS) Rule for 2027 on July 14, 2026. This announcement starts the clock for the submission of public comments on programmatic and reimbursement policies that affect physicians providing services to Medicare beneficiaries. The proposed Rule also includes proposed changes to the Merit-based Incentive Payment System (MIPS) and alternative payment model (APM) participation options and requirements for 2027.
A few notable proposals of concern include:
- Medicare payment updates that do not reflect the growth in physician practice costs.
| Medicare Conversion Factor | Medicare Anesthesia Conversion Factor | ||
|---|---|---|---|
| For APM* QPs** | For non-APM QPs | For APM QPs | For non-APM QPs |
| $33.1693 (-1.19%) | $32.8409 (-1.68%) | $20.4165 (-0.89%) | $20.2143 (-1.38%) |
*Advanced Alternative Payment Models
**Qualified Participants
- Plan to sunset traditional MIPS reporting in 2029 and transition MIPS Value Pathways (MVPs), despite repeated concerns raised by physician organizations that MIPS is unduly burdensome; disproportionately harmful to small, rural, and independent practices; exacerbates health inequities; and is not aligned with meaningful clinical outcomes.
- Reducing payment when a separately identifiable E/M visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure.
The Michigan State Medical Society (MSMS) will be thoroughly reviewing the proposed Rule in the coming weeks and preparing detailed comments for submission to CMS. MSMS encourages physicians to share your comments with CMS as well. It is important to remember that CMS reviews all comments as they work to finalize the CY2027 PFS. Therefore, comments from physicians, MSMS, the American Medical Association (AMA), and others can influence the outcome of the final Rule, which is typically released in November of each year. Comments are due by September 14, 2026, and can be submitted online.
Detailed information, links to resources, including an initial overview of the 1,600-page rule prepared by the AMA, are provided below.
Please contact Dara Barrera at djbarrera@msms.org if you have questions or would like to share specific concerns or support for any of the rule’s proposed provisions.
Resources:
- AMA Alert: 07/14/2026
- CMS Press Release
- Physician Payment Schedule Fact Sheet
- Medicare Shared Savings Program Fact Sheet
- Quality Payment Program (QPP) Fact Sheet
- Proposed Rule