07/29/2026

Submit Comments on CMS Proposed Fee Schedule Rule by September 14

The Centers for Medicare and Medicaid Services (CMS) released the proposed Physician Fee Schedule (PFS) Rule for 2027.   

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.
• 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.

It is important to remember that CMS reviews all comments as they work to finalize the CY2027 PFS. Therefore, comments from healthcare providers 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.     

• 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