The Centers for Medicare and Medicaid Services (CMS) has released the final 2027 Medicare Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System rules. Read on for early quick takes from both rules.

2027 Medicare PFS Rule

Under the final 2027 Medicare PFS, the conversion factor for practitioners participating in a qualified alternative payment model (APM) is $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 increase payments to cardiology by 0%, 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.

Other key highlights include:

• Ambulatory Specialty Model: Despite robust formal comments and multiple meetings with CMMI and CMS officials, no further substantive changes were made to the mandatory Ambulatory Specialty Model for Heart Failure. CMS finalized a process to automatically identify clinician specialty type changes through administrative enrollment data via PECOS. Impacted members are encouraged to update their specialty designation as well as prepare for the Jan.1, 2027 launch by viewing materials on ACC.org. Additional efforts to assist ASM participants will continue.
• Remote Physiologic Monitoring: CMS modified its plan to entirely overhaul coding and payment for remote physiologic monitoring services. It will allow third-party vendors to provide RPM technical services until Jan. 1, 2029, and will continue to use the existing CPT codes with reduced practice expense inputs in 2027.
• G2211: CMS finalized its plan to eliminate code G2211 for longitudinal care complexity and instead create modifiers that will increase the payment of the base E/M code by 16%. The ACC explained in its comments that revenue will still flow to practices under that proposal, but it will not be attributable to individual clinicians via relative value units (RVUs), complicating compensation decisions.
• 25 Modifier with 0-, 10- and 90-day Global Codes: Responding to comments from the public and ACC, CMS modified its proposal to reduce by 50% the payment for lower-valued second and subsequent services provided on the same day with an E/M. Instead, the policy will apply only to 0-day services on the same day as an E/M and the reduction will be 20%.
• SaaS to SaMS: 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 is deeply disappointed that CMS finalized several policies that will make it harder for cardiovascular clinicians to deliver the care their patients need. At a time when cardiology practices continue to face significant cost pressures, inadequate recognition of inflationary pressures, implementation of the Ambulatory Specialty Model without additional testing, reductions in payment for key cardiovascular services, and restrictions on remote physiologic monitoring risk reducing access to essential cardiovascular services and adding further strain to the health care system," said ACC President Roxana Mehran, MD, FACC. "The ACC will continue to work with Congress and CMS on solutions that protect patients, support clinicians and strengthen the long-term stability of cardiovascular care."

2027 Hospital OPPS and ASC Payment Rule

The 2027 Hospital OPPS and ASC Payment System final rule includes a 2.3% increase to OPPS payment rates that reflects a market basket update of 3.2% reduced by a productivity adjustment of 0.9%. Other provisions of note include:

• Site-Neutral Payment for Imaging without Contrast: CMS finalized its proposal to pay for imaging services without contrast provided at previously "excepted" hospital off-campus provider-based departments at a lower rate similar to the Medicare Physician Fee Schedule.
• PET/CT APC Assignments: CMS finalized changes to reorganize nuclear imaging APCs such that PET/CT services are now assigned to clinical Ambulatory Payment Classifications (APCs) rather than new technology APCs. This change makes payment more stable for PET/CT services and does not greatly disrupt the APC families.
• 340B Drugs Payments: Payment for drugs acquired through the 340B program will be reduced from Average Sales Price (ASP) plus 6% to ASP minus 28% to align with a drug acquisition cost survey completed earlier this year. The initial proposal was ASP minus 33.4%.
• Inpatient-Only List/Covered Procedures List: Continuing the drive to remove obstacles that could limit access to care in different care settings, CMS advanced its plan to eliminate the inpatient-only (IPO) list by 2029, removing 637 services for auditory, digestive, endocrine, female genital, hemic and lymphatic systems, integumentary, male genital, maternity care and delivery, mediastinum and diaphragm, respiratory, and urinary services from the IPO. Separately, 619 services were added to the ASC Covered Procedures List (CPL), including nearly all of the services removed from the IPO.
• Software as a Medical Service: As with the final Medicare PFS, 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).

Additional Resources

Access the final Medicare PFS Press Release, Fact Sheet, Related Addenda, and a Medicare Shared Savings Program Fact Sheet. Access the final Hospital OPPS Press Release, OPPS Fact Sheet, and Addenda. Looking for more on the proposed rules? Explore ACC's Guide to the 2027 Medicare Rules.

ACC Advocacy staff will provide more detailed breakdowns of both final rules in the coming days. Look for additional 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