CMS releases 2027 Medicare Physician Fee Schedule proposed rule

The Centers for Medicare & Medicaid Services released the calendar year 2027 Medicare Physician Fee Schedule proposed rule July 14, outlining proposed payment and policy changes for Medicare Part B services effective in January 2027. For infectious diseases physicians, the release is an important early signal on physician payment, practice expense policy and Medicare quality reporting.

CMS proposes separate conversion factors for qualifying Alternative Payment Model (APM) participants and nonqualifying clinicians and continues broader changes to PE methodology that could affect how overhead is recognized for office-based care.

Of particular interest to ID physicians, CMS appears to be continuing its effort to modernize PE policy, including a proposal to phase out the indirect PE index, which has relied on older survey data, while also maintaining policies such as direct supervision through real-time audio/video technology and an Infectious Disease specialty set within the Merit-Based Incentive Payment System (MIPS). More specifically, CMS proposes to remove, over a two-year transition, the PE methodology steps that rely on the indirect PE index, stating that those steps depend on increasingly dated specialty-level survey data and can override more current code-level inputs and allocators. In addition, CMS is seeking comment on the 50% indirect PE allocation for facility-based physicians that was finalized for CY 2026, including whether that amount is accurate or could be lower for hospital-employed physicians whose overhead may already be reflected in hospital payment systems.

However, even though CMS estimates a 0% aggregate specialty impact for ID from the proposed relative value unit changes, ID physicians would still be affected by the proposed CY 2027 conversion factor reductions to about $33.17 for qualifying APM physicians and about $33.03 for nonqualifying physicians, which CMS says reflect projected decreases of 1.19% and 1.68%, respectively. CMS also makes clear that the specialty impacts table does not include these separate conversion factor effects.

These proposals matter because ID physicians often provide complex, longitudinal, outpatient care that depends on appropriate recognition of clinical staff support, care coordination and other practice costs. IDSA staff is reviewing the rule in detail and will provide additional analyses, submit a comment letter to CMS on the provisions that may affect ID physicians and their patients, and advocate for congressional intervention as needed to avert or reverse policies that may harm ID physicians and to advance positive physician reimbursement reforms.

About IDSA
The Infectious Diseases Society of America is a global community of 13,000 clinicians, scientists and public health experts working together to solve humanity's smallest and greatest challenges, from tiny microbes to global outbreaks. Rooted in science, committed to health equity and driven by curiosity, our compassionate and knowledgeable members safeguard the health of individuals, our communities and the world by advancing the treatment and prevention of infectious diseases. Visit idsociety.org to learn more.