CMS's CY2027 PFS would halve the lower-cost same-day E/M or procedure, and turn G2211 into a modifier

On July 14, 2026, CMS issued the CY2027 Medicare Physician Fee Schedule proposed rule, the annual notice that sets fee-for-service Part B payment and, along the way, moves a handful of coding rules that land straight on the coder's desk. Comments are due September 14, 2026, and the policies would take effect on or after January 1, 2027. Most of this is still a proposal, not settled policy. Read it now anyway, because two of the changes hit the highest-volume billing decisions a practice makes every day.

What the conversion factor does to CY2027 pay

By statute there are now two conversion factors: one for qualifying alternative payment model (APM) participants, one for everyone else. CMS proposes the numbers below. The decrease is not a new cut so much as the sunset of an old bump: Public Law 119-21, which CMS calls the Working Families Tax Cut law, gave a one-year 2.50% increase for CY2026 that no longer applies in CY2027.

A lower conversion factor lowers the payable amount on every service, so the coding changes below sit on top of an already-tighter baseline.

The same-day E/M and global-surgery change is the one to model first

For CY2027, CMS proposes that when a separately identifiable office/outpatient 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 most expensive service is paid at 100% and every other surgical procedure or E/M visit that day is paid at 50%.

This one has the widest reach. It hits the modifier 25 scenario a busy procedural schedule bills all day long. CMS's read: when the same practice does the E/M and the procedure on the same day, the work overlaps, so paying both in full is "likely duplicating payment." It floated the same idea in the CY2019 proposed rule and backed off. This time it's proposed on its own.

G2211 becomes a modifier, and ACOs get a second one

CMS finalized separate payment for the office/outpatient E/M visit complexity add-on, HCPCS code G2211, in CY2021, delayed it, and implemented it for CY2025. For CY2027 it proposes to stop paying G2211 as a standalone code and instead recognize it as a modifier appended to the base E/M code. The modifier would raise the associated E/M payment by 16% across all E/M levels, a percentage instead of the current flat add-on amount.

There is a second, ACO-only modifier in the proposal. For practitioners in a Shared Savings Program ACO or a Long-term Enhanced ACO Design (LEAD) Model ACO, a separate modifier would raise the associated E/M payment by 32% to recognize longitudinal-care work. CMS describes it as voluntary and billable for all beneficiaries the ACO practitioner serves, not only assigned ones.

Advance care planning splits into practitioner and clinical-staff codes

CMS proposes to create two new HCPCS codes for advance care planning (ACP) furnished by clinical staff under the direct supervision of the billing practitioner, and to restrict the existing ACP codes, CPT 99497 and 99498, to time the billing practitioner personally spends. If your notes don't already flag who did the ACP work, start capturing that split now so the codes map cleanly if the proposal is finalized.

Remote monitoring tightens

CMS proposes several changes to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM):

• RTM would be furnished only to established patients.
• A practitioner reporting RPM or RTM would have to furnish a separately reportable initiating visit at the onset of the service.
• Payment would be allowed only when the service is performed by clinical staff employed by the practice, not by contractors.

CMS also says it is considering bundling the RPM and RTM CPT codes and creating four new HCPCS G-codes for remote monitoring, an approach it links to recommendations from recent OIG reports. If a device vendor supplies the monitoring staff for your practice, the contractor limit is the line to read closely.

Other coding CMS is proposing to create

A few smaller items round out the coding-relevant proposals:

• Shared medical appointments. No HCPCS code currently describes them; CMS proposes to establish separate coding and payment.
• Behavioral health transition. CMS proposes to include smoking and tobacco use cessation and SBIRT (screening, brief intervention, and referral to treatment) services in the final year of the timed behavioral health work-RVU transition.
• RHC and FQHC. CMS proposes to recognize Diabetes Self-Management Training and Medical Nutrition Therapy as stand-alone billable RHC visits, and to extend the waiver of in-person requirements for mental health visits at RHCs and FQHCs through December 31, 2027, consistent with the Consolidated Appropriations Act, 2026.

This is a proposal, and the window closes September 14

None of this is final yet. CMS is taking comments through September 14, 2026, and usually publishes the final rule late in the fall for a January 1 effective date. The same pattern applies here as with the quarterly NCCI edits: the change files and notices are public well ahead of the effective date, and the practices that get surprised are the ones that read them off a denial rather than off the source. Read the proposals that touch your service mix, model the same-day E/M reduction against your own claims, and confirm any code you are about to rebuild a rule around in the Code Book or against a specific encounter in the encoder. None of this changes Medicare Advantage risk adjustment, which runs on a separate track from the fee schedule.