The 2027 Medicare Physician Fee Schedule (PFS) final rule released by the Centers for Medicare and Medicaid Services (CMS) on Nov. 3 includes a number of provisions important to cardiology. ACC Advocacy has developed the following overview addressing some of the most important highlights.

Physician Reimbursement

The final rule includes a conversion factor for practitioners participating in a qualified alternative payment model (APM) of $32.9548, a 1.86% decrease from 2026. For practitioners not participating in an APM, the conversion factor is $32.6286, a 2.36% decrease from 2026. CMS estimates the impact of finalized proposals will hold payment flat for cardiology, though impacts will be largely dependent on patient and service mix. Individuals and groups will see different impacts depending on patient populations and services offered.

Budget neutrality-related cuts have significantly impacted physicians in recent years. The 2.36% cut to the conversion factor for 2027 follows the −2.5% “efficiency adjustment” implemented in 2026 and cuts of 2.8% in 2025, 2% in 2024, nearly 2% in 2023, 0.8% in 2022 and 3.3% in 2021. While Congress provided a 2.5% update in 2026 to offset cuts, this update expires at the end of this year. Combined with the failure to account for significant inflation in practice costs, this trend creates long-term financial instability in the Medicare physician payment system, threatening patient access to Medicare-participating physicians and services.

Advocating for comprehensive, long-term reform of the Medicare payment system is a key ACC Advocacy priority. Throughout this year, the College has submitted several statements for the record ahead of key congressional hearings and met with lawmakers serving on committees with jurisdiction over health care policy. In collaboration with the broader medical community, these efforts helped secure the reintroduction of the Strengthening Medicare for Patients and Providers Act (H.R. 6160), which would provide annual inflationary updates tied to the Medicare Economic Index, and the Provider Reimbursement Stability Act (H.R. 8163), which would increase the budget neutrality threshold from $20 million to $54 million. The latter bill passed unanimously out of the U.S. House Ways and Means Committee and was also a key focus of a recent U.S. House Energy & Commerce Committee hearing on payment policy. We will continue to advocate for passage of these critical reforms during the lame duck session of Congress.

The ACC is also working to prevent further implementation of the −2.5% efficiency adjustment, introduced in the 2026 Medicare PFS final rule and upheld in this year’s rule. ACC Advocacy has participated in over 50 coalition meetings with congressional offices in support of the Efficiency Adjustment Delay Act (H.R. 7520) and joined numerous multi-societal letters that urged policymakers to address the issue and protect physician reimbursement.

The College will also continue to explore and promote approaches to stabilize the health care system and foster a successful, widespread transition to value-based care that reflects the needs of cardiovascular patients and clinicians in every setting. Learn more about ACC’s ongoing efforts to establish sustainable Medicare payment practices and how to get involved.

Ambulatory Specialty Model

• CMS declined ACC’s recommendation to delay the ASM implementation date or establish a six-to-12-month transition/test period. The first performance year for selected ASM participants will begin as proposed, on Jan. 1, 2027. Payment adjustments for participants will be applied in 2029.
• CMS determined that ASM participants who meet eligibility criteria for a performance year will remain in the model throughout the testing period, with possible exceptions for changes in taxpayer identification number (TIN) or specialty designation.
• CMS finalized the exception process for TIN changes and specialty designation and removed the physician notification requirement. As a result of ACC’s effort to reduce administrative burden associated with ASM, the agency plans to use the administrative claims and enrollment data to determine and notify the clinician of their eligibility for these exceptions.
• CMS finalized the effect and duration of the TIN-based and specialty type exceptions.
• CMS finalized that ASM participants in designated small practices will have the flexibility to report their quality measure data at either the group (TIN) or individual level.
• The agency agreed to allow ASM participants to attest to completing ASM improvement activities at either the group (that is, TIN) level or the individual (that is, TIN/NPI) level.
• CMS declined to establish a voluntary PRO data submission opportunity and associated quality ASM performance category scoring incentive.
• CMS finalized incorporating the rural scoring adjustment into the final score formula.

The College has had significant ongoing engagement with policymakers to recommend approaches to best enable selected participants to succeed in the ASM. Outreach and education on the mandatory ASM continue through emails and postcards to selected participants, along with state chapter engagement. The ACC ASM Practical Guide incorporating elements and recommendations from the AHA/ACC HF Guideline is currently available at ACC.org/ASMforHF.

Physician Fee Schedule Values

• Left Atrial Appendage Occlusion (LAAO): LAAO CPT code 33340 was reduced from the RUC recommended value of 9.99 to 9.00 in the final rule with CMS noting reduction in intra-service time as the rationale.
• Tricuspid Valve Repair and Replacement: CMS finalized the proposed work RVUs for the newly created tricuspid repair and replacement codes which were 28% below the RUC recommended values.
• Cardiac Contractility Modulation: 11 new implantation/removal codes and four new programming and interrogation codes for cardiac contractility modulation were finalized at RUC recommended work RVUs.
• Drug-Coated Balloon Services: CMS had proposed to reduce the RUC recommended work RVU for the newly created drug-coated balloon angioplasty code from 10.00 work RVUs to 8.05 which would value the service below a standard balloon angioplasty (92920 – 8.14 work RVUs). ACC and other stakeholders argued for the RUC recommended value or a crosswalk to stent code 92928 at 9.75 work RVUs. Ultimately, CMS acknowledged the concern of valuing the new, multi-step angioplasty below the standard and finalized the value for the new drug-coated balloon angioplasty at 8.62 work RVUs.
• Coronary IVUS: CMS finalized reductions to the RUC recommendations for coronary IVUS code 92978 by 18% from 1.76 work RVUs to 1.40, and 92979 by 24% from 1.40 work RVUs to 1.06.
• Practice Expense Formula: CMS finalized its proposal to execute a two-year shift away from indirect practice expense (PE) calculations based on prior American Medical Association surveys to a system that can be routinely updated and audited. The ACC expressed concern about this and other proposed methodological changes, recommending greater transparency and more time for stakeholders to assess the validity of the proposals and the potential impacts on care. Individual services will generally see PE RVUs change modestly as a result of these shifts. It is difficult to isolate the impacts because multiple adjustments are happening at the same time.

Remote Physiologic Monitoring (RPM)

CMS proposed to reduce the practice expense inputs for RPM codes, condense the family of 19 codes down to four G codes, require initiating visit to bill for RPM services, and ban payment for RPM services if managed by a third-party vendor beginning Jan. 1, 2027. The final rule reduced the practice expense inputs for these services, requires initiating visit, did not condense the family of codes and the ban on third-party vendors was delayed until Jan. 1, 2029.

G2211

CMS finalized its proposal to replace the G2211 E/M complexity add-on code with two modifiers, despite ACC requests to consider alternatives as G2211 provided work RVUs that could be attributed to a physician’s work productivity related to compensation while additional payment from modifiers would not.

Beginning Jan. 1, 2027, modifier B1 can be used in the same manner as G2211 and will add 16% to the E/M payment for providers not participating in an ACO or LEAD model. Similarly, modifier B2 can be used in the same manner as G2211 was and will add 32% to the E/M payment for providers that do participate in an ACO or LEAD model.

25 Modifier with Global Period Codes

CMS proposed that when an E/M code billed with the 25 modifier on the same day as a 0, 10 or 90-day global period service, payment for the lower-valued service would be reduced by 50%. In consideration of comments from the ACC and many other medical societies and stakeholders, CMS amended this policy as part of the final PFS rule. The finalized policy reduces these payments by 20% and will apply only to 0-day global period codes.

Shared Medical Appointments

CMS is finalizing creation of the following two G codes for shared medical appointments (SMAs):

• G0686 will be a base code applying to SMAs for 2–10 patients for up to 60 minutes with a work RVU of 1.73 (per patient).
• G0687 will be an add-on code for each additional 30 minutes of time spent with the patients with a work RVU of 0.87 per unit. A maximum of two units of G0687 can be billed per session which would include a total time of two hours for the SMA and a total combined work RVU of 3.47 (per patient).

Telehealth Provisions

Following the passage of 2026 funding legislation, telehealth flexibilities allowing Medicare beneficiaries to receive services in their homes were extended through December 2027, and CMS finalized regulations aligning with those dates. In addition, CMS created new billing modifiers for certain telehealth arrangements and finalized greater flexibility for teaching physicians to bill for telehealth services involving residents when either the physician or resident is physically with the patient.

Quality Payment Program

• CMS delayed the retirement of traditional MIPS from the 2029 to the 2031 performance period. Mandatory MVP reporting will begin in 2031.
• CMS finalized the core-measure approach, including mechanisms for clinicians to attest when a core measure is not applicable and use an alternative, subject to final specifications. These would apply to all MVPs.
• CMS adopted the Hypertension MVP as proposed.
• Removed the Improvement Activity, IA_PM_2, Anticoagulant Management Improvements, from the IA inventory.
• Adoption of the Electronic prior authorization for medical services measure, finalizing the transitional, optional approach with bonus treatment for the medical-items-and-services measure.
• Adoption of the Electronic prior authorization for prescription drugs measure, with some exclusions for reporting.
• CMS finalized relief from the seven-point cap for qualifying required measures under the defined topped-out benchmark policy.
• Quality ID #438 – CMS expanded the clinical ASCVD population; removed prediabetes and the pregnancy exclusion and moved to an overall alignment with current guidelines.

Access the CMS QPP Fact Sheet for more information.

Medicare Shared Savings Program (MSSP)

CMS finalized a more flexible ACO-specific CEHRT framework, including pathways tied to electronic measure reporting, certified health IT, and designated CEHRT-use activities or attestations. View the CMS MSSP Fact Sheet.

Health IT

• CMS finalized its proposal to change terminology for algorithm-based software services paid under Medicare from “Software as a Service” (SaaS) to “Software as a Medical Service” (SaMS). The ACC was supportive of the change in terminology and recommended that CMS promote transparency and strong evidentiary standards for SaMS tools and encourages a total product lifecycle evaluation process for these tools.
• Addressing the RFI on Duplicate Laboratory Testing, Imaging, and Result-Sharing and Interoperability, CMS noted that commenters generally supported reducing unnecessary duplicate testing but opposed payment denials when repeat tests are clinically necessary or prior results are unavailable. The agency did not announce next steps. The ACC, as part of its response to the RFI, supported increasing interoperability and exchange of laboratory testing and imaging data which are crucial in CV care. The College also encouraged CMS to address underlying interoperability issues before administering payment consequences when repeat testing is necessary in providing quality care.
• Under MIPS program updates, CMS updated and modified the definition of Certified Electronic Health Record Technology (CEHRT) to align with the applicable ONC proposals to remove certain certification criteria from the ONC Health IT Certification Program as outlined in the Health Data, Technology, and Interoperability: ONC Deregulatory Actions to Unleash Prosperity (HTI-5) final rule.

Resources

Additional information on the final rule can be found in the Medicare PFS Press Release, Fact Sheet, and Addenda. ACC Advocacy staff will provide additional analysis as needed. Look for updated information on ACC.org/Advocacy and in upcoming issues of the ACC Advocate newsletter.

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Fee Schedules