The public comment period for the calendar year 2027 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) proposed rule closed on September 14, 2026. The Michigan State Medical Society (MSMS) submitted comments on a number of key provisions with the potential to impact care delivery, physician reimbursement, and patient access.
The MSMS letter stressed ongoing concerns about practice sustainability, noting that Medicare physician payment declined 33 percent from 2001 to 2025 when adjusted for inflation in practice costs. MSMS also expressed concern that several proposals in the proposed MPFS rule could further undermine the financial viability of independent physician practices and limit timely and convenient access to care for Medicare beneficiaries if finalized as presented.
Key provisions highlighted by MSMS include:
- Global Procedure and Same-Day Evaluation and Management (E/M) Visit — MSMS opposes finalizing proposals to reduce 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. Under the proposal, the Centers for Medicare and Medicaid Services (CMS) would pay the most expensive service, whether a surgical procedure or E/M visit, at 100 percent and the other surgical procedure or E/M visit furnished on the same day at 50 percent.
- Maternity Care Services — MSMS supports CMS’s proposal to adopt the American Medical Association’s revised maternity care services coding structure beginning January 1, 2027. These changes reflect modern obstetric practice by providing greater specificity and clarity across antepartum, labor and delivery, and postpartum care.
- Remote Monitoring — MSMS is concerned about the impact of several CMS proposals that could unnecessarily restrict physician practices' ability to provide remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services and undermine patient access to effective remote monitoring. Oppose finagling CMS’s proposal to limit payment for RPM and RTM services to clinical staff employed directly by the billing physician or practice.
- Transition from MIPS to MVPs — MSMS opposes mandating Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) beginning in 2029 until there is evidence of a more clinically relevant, patient-centered reporting framework.
Additional topics included in the comment letter:
- Practice Expense Methodology
- Healthcare Common Procedure Coding System (HCPCS) Code G2211 Redesign
- Telehealth
- Medicare Shared Savings Program (MSSP) and Accountable Care Organization (ACO) Enhancements
- Primary Care Valuation
- Current Procedural Terminology (CPT)
If you have questions or need further information, please contact Stacey P. Hettiger, MSMS Senior Director of Advocacy and Payor Relations, at shettiger@msms.org or 517-336-5766.