CMS Proposed Reimbursement Changes Raise Concerns for Surgeons

On July 14, the Centers for Medicare & Medicaid Services (CMS) released the 2027 Medicare Physician Fee Schedule (MPFS) proposed rule, which includes payment reductions and several policy changes that could significantly affect surgeon reimbursement, surgical practice, and Medicare quality programs.

CMS proposes reducing the Medicare conversion factor by 1.19% for qualifying Alternative Payment Model (APM) participants and 1.68% for all other physicians. While these reductions largely reflect the expiration of the temporary payment update Congress provided for 2026, the proposal extends far beyond the annual payment update.

The agency proposes reducing payment for separately identifiable evaluation and management (E/M) visits provided on the same day as a global surgical procedure and seeks comments on changes that could further diminish physician input into how physician services are valued. Although CMS did not propose cuts to global codes for calendar year 2027, the agency signals continued interest in revaluing global surgical codes by reopening questions about the postoperative visits included in global payments.

The proposed rule also includes significant changes to Medicare's Quality Payment Program. CMS proposes phasing out traditional Merit-Based Incentive Payment System (MIPS) after the 2028 performance year, making MIPS Value Pathways (MVPs) the primary reporting option for clinicians who are not participating in Advanced APMs beginning in 2029.

While CMS proposes several MVPs relevant to surgical specialties and seeks input on the future role of specialty care and digital quality measurement, these changes represent another significant shift in surgeon participation in Medicare quality programs.

The ACS will submit comments addressing these concerning MPFS provisions before the public comment period closes on September 14. Read more about the MPFS proposed rule.