On September 11, the Endocrine Society submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on the Calendar Year 2027 proposed Medicare Physician Fee Schedule (MPFS) rule. The MPFS is published annually and sets payment policies and payment rates for Part B services furnished under the MPFS. The Society’s letter addressed several provisions in the proposed rule that it identifies as particularly important to practicing endocrinologists.
The proposed rule, if finalized as published, would produce mixed impacts: a reported 2.5% increase for the endocrinology specialty but an overall 2.5% decrease to the conversion factor applied to all physicians. The Society highlighted that the conversion factor change requires congressional intervention to be updated and reiterated its position urging Congress to enact legislation that would provide an annual inflationary update to the MPFS tied to the Medicare Economic Index (MEI). Such legislation, the Society argues, would override the negative impact of the proposed rule and better preserve payment levels for clinical practices.
Among the proposals in the rule, CMS suggested creating a new practice expense equipment item for Fine Needle Aspiration (FNA), designated ER130: “Fine Needle Aspiration portable ultrasound.” The Endocrine Society supported this change and described it as an important update to the practice expense inputs for FNA services. The Society noted it had worked with other medical societies during the CPT and RUC processes to advance this adjustment. The Society characterized the CMS proposal as an advocacy success that benefits endocrinologists who perform FNAs by recognizing relevant equipment costs in practice expense calculations.
CMS proposed deleting the recently created G2211 complex care code and replacing it with a new modifier, referred to in the proposed rule as MOD1. Under the CMS proposal, when MOD1 is appended to an appropriate evaluation and management (E/M) CPT code, it would increase payment by 16% of the value of the reported E/M code.
The Society expressed deep concern regarding the potential impact of this change on work relative value units (work RVUs). Specifically, the Society warned that replacing G2211 with a modifier-based approach could lead to a loss of work RVUs for physicians who practice within larger hospital systems and university settings. In its comments, the Society urged CMS not to finalize the proposal and recommended that the agency retain the G2211 code rather than adopt the MOD1 modifier structure.
Separately, CMS proposed a policy that would reduce payment when a Modifier 25 is used in certain circumstances in combination with an E/M visit. The Endocrine Society asked CMS not to finalize this reduction in payment tied to Modifier 25 usage. The letter conveyed the Society’s concerns that the proposed change could negatively affect appropriate billing for distinct services provided on the same day as an E/M visit, but the source article does not provide additional details on the specific circumstances CMS described.
The Society’s submission was prepared by Endocrine Society staff in close collaboration with the Clinical Affairs Core Committee (CACC). The Society thanked the CACC for its feedback and collaboration on drafting the comments. The article states that the final MPFS rule was expected to be released by early November at the latest. The Society’s full comment letter was made publicly available at endocrine.org/advocacy/society-letters.
Note: This rewritten summary reflects only the facts reported in the source article. The article did not include the full text of the Society’s letter within its body, details beyond the proposals summarized here, or specific CMS regulatory language and rationale for each proposal.