On July 14, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2027 Medicare Physician Fee Schedule (MPFS) proposed rule. CMS posted a fact sheet on the proposed rule on its website. The Endocrine Society highlighted provisions of particular interest to endocrinologists and indicated it will publish a more detailed analysis for members in August.
CMS annually issues the MPFS proposed rule and solicits public comment. The Endocrine Society plans to submit a formal comment letter in response to the proposal. The deadline for submitting comments on this proposed rule is September 14.
CMS estimated that the overall set of proposals in the CY 2027 MPFS would result in a 2.5% decrease in reimbursement across all physicians. However, the agency also estimated that policies in the rule would lead to a 2.5% increase in payment for the endocrinology specialty.
According to the Society’s summary, the positive change for endocrinology reflects several proposals that favor non-procedural practitioners over procedural practitioners, including changes in the treatment of add-on coding and valuation of specific services used more frequently by endocrinologists.
A significant change proposed by CMS is converting the current G2211 complex visit add-on code into a modifier labeled MOD1. The proposed MOD1 would retain the same descriptor as the existing G-code and could be reported and billed in the same manner as the current G2211.
When the MOD1 modifier is appended to an appropriate evaluation and management (E/M) code, CMS proposes reimbursing it at 16% of the value of the billed E/M code. This change is part of CMS’s approach to recognize complexity in E/M encounters while altering the code structure from a G-code to a modifier.
The proposed MPFS includes an increase in the reimbursement rate for Fine Needle Aspiration (FNA). The Endocrine Society advocated for raising FNA reimbursement and reported that CMS is proposing this adjustment in the rule. The Society expressed approval that CMS is proposing to increase the FNA rate.
CMS proposed a policy change affecting remote monitoring services. Under the proposal, practitioners who provide remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services would be required to conduct a separately reportable initiating visit prior to starting RPM or RTM. That initiating visit could be performed either in-person or via telehealth and must be separately reportable from the monitoring services themselves.
This requirement reflects CMS’s effort to define the clinical initiation of remote monitoring programs and clarify billing expectations for those services.
Separately from the MPFS rulemaking, bipartisan chairs of the GOP and Democratic Doctors Caucus introduced the Patients First Act on July 15. The legislation would reform Medicare physician payment by establishing an annual inflationary update to the MPFS tied to the Medicare Economic Index (MEI).
The Patients First Act would set the update at MEI minus 1%. The Endocrine Society has urged the bill sponsors to ensure endocrinologists and other non-procedural specialists who primarily bill E/M services are supported under the proposal.
CMS’s fact sheet on the proposed CY 2027 MPFS is available on the agency’s website. The Endocrine Society will publish an in-depth analysis of the proposed rule for members in August and intends to submit a comment letter to CMS ahead of the September 14 comment deadline.
Members and stakeholders who wish to review the proposal or submit comments directly should consult CMS’s public materials and follow the formal comment process described in the proposed rule and fact sheet.
The Society emphasized continued advocacy for adequate reimbursement for endocrinologists and related specialties. Specific priorities noted in the Society’s summary include supporting the proposed increase in Fine Needle Aspiration reimbursement, monitoring the implementation and valuation of the G2211 transition to MOD1, and ensuring that any legislative or regulatory reforms recognize the care needs and billing patterns of non-procedural specialists who rely on E/M services.
The Endocrine Society will continue to engage with lawmakers and CMS as the rulemaking and legislative processes proceed, and will provide guidance and analysis for members as additional details become available.