Federal Rulemaking, CY2027 PFS, CMS-1848-P
The answer first: CMS has proposed cutting the 2027 Medicare Physician Fee Schedule conversion factor to $32.8409 for clinicians who are not qualifying APM participants, a 1.68 percent reduction, and to $33.1693 for qualifying APM participants (QPs), a 1.19 percent reduction. The proposal appears in the Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule, file code CMS-1848-P, announced in a CMS fact sheet issued July 14, 2026 and published in the Federal Register on July 16, 2026. The driver is simple: the one-year 2.50 percent payment increase enacted in Public Law 119-21 applies only to CY2026 and expires when the year ends. Comments are due September 14, 2026.
The two numbers your CY2027 budget hangs on
Applies to clinicians who are not qualifying APM participants. Statutory update: +0.25 percent.
Applies to qualifying APM participants. Statutory update: +0.75 percent.
SOURCE: CMS FACT SHEET, CY2027 PFS PROPOSED RULE (CMS-1848-P), JULY 14, 2026
Why the conversion factor drops again
Nothing exotic happened. Three mechanical facts stack into the cut, and each one is visible in the proposed rule itself.
The 2.50% bump expires
Public Law 119-21 gave physician payment a one-year 2.50 percent increase for CY2026 only. Congress wrote it as temporary, and CMS cannot extend it by regulation. It falls out of the CY2027 baseline automatically.
Statute splits the update
For CY2027, statute provides a +0.75 percent update for QPs and a +0.25 percent update for non-QPs. This is the first full year the two tracks diverge in the conversion factor itself.
The net is negative
The small statutory updates cannot offset the loss of the 2.50 percent bump. The proposed result: −1.19 percent for QPs and −1.68 percent for everyone else.
The dates that matter
Fact sheet issued
CMS releases the CY2027 PFS Proposed Rule fact sheet (cms.gov/newsroom/fact-sheets) with both proposed conversion factors.
Federal Register publication
CMS-1848-P publishes in the Federal Register, starting the formal comment clock.
Comments close
Comments due at regulations.gov under file code CMS-1848-P. After this, you are an observer, not a participant.
What billing teams should do with this now
A conversion factor cut is not an abstract policy event. Medicare payment for a code is its total RVUs multiplied by the conversion factor, so a 1.68 percent cut to the factor flows through to every single line you bill to Medicare. Two factors now exist, which means every group needs two models, and every clinician needs a QP determination before you can say which model applies to them. The concentration risk sits where it always does, in office visit E/M codes, because that is where most groups stack their Medicare volume. A modest per-visit reduction multiplied across your highest volume E/M lines is where the real CY2027 dollars move.
This is a proposed rule, not a final one. The numbers can change before the final rule lands this fall, and Congress has intervened on the conversion factor before. But the modeling work is identical either way, and teams that wait for the final rule to start will be building budgets in December.
- Pull your top 25 Medicare codes by allowed volume and reprice each at $32.8409 and at $33.1693. Two columns, one spreadsheet, done this month.
- Confirm QP status for every rendering clinician. The gap between the two factors is real money, and you cannot model revenue until you know which factor each NPI earns.
- Flag your high-volume E/M lines specifically. Office visits are where the cut concentrates. Quantify the delta per visit and per year at current volumes.
- Brief leadership on the CY2027 budget impact before contract renewals and staffing plans lock. A cut you modeled in August is a plan; one you discover in January is a crisis.
- File a comment by September 14, 2026 at regulations.gov under file code CMS-1848-P if the cut materially harms your specialty mix. Specific, data-backed comments carry more weight than form letters.
- Recheck commercial contracts tied to Medicare rates. Any fee schedule defined as a percentage of Medicare moves when the conversion factor moves.
Sources cited
- CMS fact sheet, Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P), issued July 14, 2026, cms.gov/newsroom/fact-sheets.
- Federal Register publication of CMS-1848-P, July 16, 2026.
- Comment docket: regulations.gov, file code CMS-1848-P, comment period closes September 14, 2026.
- Public Law 119-21, the source of the one-year 2.50 percent CY2026 payment increase.
Model the cut before it models you
ASP-RCM Solutions builds per-code CY2027 impact models for physician groups: your real Medicare volumes repriced at both proposed conversion factors, QP status mapped per clinician, and E/M concentration flagged line by line, backed by coding accuracy of 95 percent or higher. If the CY2027 PFS is going to move your revenue, know the number now, while the comment window is still open.
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