10 parts of Medicare's 2027 pay proposal worth commenting on

Almost everything practices will be angry about next January is still changeable this week. CMS issued the CY 2027 Medicare Physician Fee Schedule proposed rule on July 14, and the 60-day comment period closes at the end of the day on Sept. 14. After that, the agency writes the final rule and practices live with it.

The number that gets quoted is the conversion factor. CMS proposes $32.8409 for practitioners who are not qualifying alternative payment model participants, a drop of 1.68 percent, and $33.1693 for those who are. But the conversion factor is largely a matter of statute, and the pieces of the rule with real discretion behind them sit further down: a 50 percent payment cut on same-day evaluation and management visits, a rebuilt G2211, a multi-year overhaul of practice expense methodology, new limits on remote monitoring and an expiration date for traditional MIPS.

CMS reads what it receives, and comment files on technical proposals are thin. A letter with claims volumes, staffing costs and specific patient consequences carries more weight than a position statement, and it does not have to be long. Our handbook on the 2027 Medicare Physician Fee Schedule walks through how each piece of the proposal reaches a practice's bottom line. Here are 10 places to start.