The Centers for Medicare and Medicaid Services (CMS) released the 2027 Medicare Physician Fee Schedule (PFS) proposed rule on July 14, reducing the PFS conversion factor from $33.5675 to $33.1693 for qualifying alternative payment model (APM) participants and from $33.4009 to $32.8409 for non-qualifying APM participants.

The overall reimbursement for cardiovascular services is projected to increase roughly 1% compared with 2026, including changes to policies and individual service values. Individuals and groups will see different impacts depending on patient populations and services offered.

Throughout the year, the College submitted several statements for the record ahead of key congressional hearings and met with lawmakers serving on committees with jurisdiction over health care policy to advocate for comprehensive, long-term reform of the Medicare payment system.

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 $53 million. Notably, the Provider Reimbursement Stability Act passed unanimously out of the U.S. House Ways and Means Committee and now awaits consideration by the full House.

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 proposed 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 multisociety letters urging policymakers to address the issue and protect physician reimbursement.

Highlights from the proposed rule relevant to cardiovascular clinicians are below.

Ambulatory Specialty Model (ASM):

• CMS clarifies that selected ASM participants who become ineligible for ASM remain subject to payment adjustments tied to performance completed during prior ASM performance years.
• ASM heart failure participants who meet certain specialty type redesignation (through PECOS or CMS-855) and notification requirements may be exempted from specified model requirements.
• The proposed rule formalizes an exception process for clinicians who experience Tax Identification Number (TIN) changes or other qualifying circumstances, clarifying eligibility, notification requirements and relief from certain ASM requirements.
• CMS also clarifies ASM data submission requirements for Quality Measures, Improvement Activities and Promoting Interoperability.
• Improvement Activities may be submitted at either the TIN or TIN/NPI level.
• All administrative quality measures will be scored at the TIN/NPI level.
• For small practices, CMS proposes that group-level quality reporting would override individual clinician submissions and determine the quality score for all participating ASM clinicians.
• The agency introduces the opportunity to voluntarily submit patient-reported outcome data, including PROMIS, which would add five additional points to the quality category score.
• The proposed rule also adds a rural scoring adjustment.

Specific Code Valuations:

• Tricuspid Valve: CMS proposes reducing the RUC-recommended work relative valve units (RVUs) for newly created CPT codes describing tricuspid valve implantation and transcatheter tricuspid edge-to-edge repair by more than 28%.
• Left Atrial Appendage Closure (33340): CMS proposes a 10% reduction to the work RVU for left atrial appendage closure.
• Intracoronary Drug Coated Balloon: The agency proposes valuing the new CPT code at the RUC survey 25th percentile rather than the RUC-recommended median. As a result, the procedure would receive a work RVU lower than that of a standard balloon angioplasty, a clear discrepancy of rank order and relativity within the PFS.
• Coronary IVUS: CMS proposes reducing work RVUs for coronary IVUS services by 20-25% compared with RUC-recommended values.
• Cardiac Contractility Modulation: CMS plans to accept all 11 new CPT codes at RUC-recommended rates.
• Ventricular Assist Device Implant/Removal: The agency accepts three new CPT codes at RUC-recommended values.
• Treatment of Incompetent Veins: CMS proposes accepting five of six resurveyed codes at RUC-recommended rates.

G2211:

• CMS proposes replacing the G2211 code with a modifier that will apply a 16% increase to the base code rather than a flat RVU rate.
• A separate modifier will be established for this service that will apply a 32% increase to the base code only for practitioners participating in a Shared Savings Program Accountable Care Organization (ACO) or Long-Term Enhanced ACO Design (LEAD) Model ACO.

New Codes From CMS:

• Four new G codes are proposed to replace 17 existing remote physiologic monitoring/remote therapeutic monitoring codes.
• A new G code is proposed for shared medical appointments, intended to allow up to 10 patients to be seen at a time for up to 60 minutes for chronic conditions.

E/M -25 Modifier Global Periods:

• CMS proposes imposing a 50% reduction on E/M visits billed on the same day as a 0-, 10- or 90-day global procedure when furnished by the same physician or practice.

Practice Expense Methodology:

• CMS proposes a multi-year strategy to move away from indirect practice expense calculations based on American Medical Association surveys to a system that can be routinely updated and audited.
• This complex proposal requires additional analysis to develop the College’s position.

Quality Payment Program (QPP):

• Starting with the 2029 performance period, CMS plans to sunset the traditional Merit-Based Incentive Payment System (MIPS) and only allow MIPS Value Pathway reporting.
• For those in Advanced APMs, CMS proposes to apply Qualifying APM Participant (QP) and Partial QP determinations at the Taxpayer Identification Number/National Provider Identifier (TIN/NPI) level instead of the NPI level.
• The proposed rule requests feedback on the future transition to Fast Healthcare Interoperability Resources (FHIR)-based digital quality reporting for QPP.
• CMS proposes adding an LDL-C Monitoring and Management quality measure, stewarded by the American Heart Association (AHA).
• The proposed rule removes coronary artery disease antiplatelet therapy, beta-blocker therapy and anticoagulation therapy for atrial fibrillation quality measures starting with the 2027 performance period due to measure retirement.

MIPS Value Pathways (MVPs):

• CMS is proposing three new MVPs focused on diabetes, hypertension and hospital-based care.
• The proposed rule allows virtual groups to report MVPs beginning with the 2029 performance period.
• New MIPS Core Measures have been introduced. Starting in 2027, every clinician would need to report at least one measure considered fundamental to their specialty and patient population.
• CMS also requests feedback on a scoring methodology to fairly compare performance of clinicians within the same MVP.

Medicare Shared Savings Program (MSSP):

• The agency seeks information on transitioning quality measures and reporting processes to FHIR-based digital approaches for Shared Savings Program ACOs.
• CMS proposes changes to the Shared Savings Program’s financial methodology to balance incentives between Level E of the BASIC track and the ENHANCED track, mitigate selection issues, benchmark rebasing concerns, and encourage participation by ACOs with higher risk and higher cost populations. 

Telehealth:

• 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 is proposing related policy updates.
• CMS’ proposal includes new billing modifiers for certain telehealth arrangements and greater flexibility for teaching physicians to bill for telehealth services involving residents when either the physician or resident is physically with the patient.

Health IT:

• CMS proposes replacing the term “Software as a Service” with “Software as a Medical Service” (SaMS).
• SaMS refers to software-based technologies that support clinical decision-making through algorithmic analysis, including those that provide clinical or diagnostic functionality.
• CMS proposes contractor pricing for 10 HCPCS codes describing various SaMS analyses performed on laboratory tests under the PFS as opposed to the Clinical Laboratory Fee Schedule.
• The proposed rule updates the definition of Certified Electronic Health Record Technology (CEHRT) to align with changes proposed separately by the Office of the National Coordinator for Health IT (ONC). Specifically, CMS proposes removing several criteria from the MIPS CEHRT definition starting with the 2027 MIPS performance year.
• In previous rulemaking, ONC proposed removing 34 certification criteria and revising seven criteria to reduce maintenance and certification burden.
• For the 2027 MIPS performance year, CMS proposes electronic prior authorization for medical items and services would be optional.
• A physician who successfully reports the measure could receive 10 MIPS Promoting Interoperability bonus points, and there is no penalty for physicians who do not report the measure.
• In the 2028 MIPS performance year, the agency plans to make the measure mandatory, requiring physicians to use all three certified capabilities (CRD, DTR and PAS) as part of the same prior authorization workflow.
• Failure to report “yes” or qualify for an exclusion in 2028 MIPS performance year could result in a zero for the entire MIPS Promoting Interoperability category.
• CMS also proposes a separate required prescription drug prior authorization measure beginning with the 2028 MIPS performance year.

Requests For Information:

• The agency is seeking input on CPT/RUC/practice expense data.
• CMS is considering a broader transition from current quality reporting formats to FHIR-based digital quality measures (dQM). The agency is looking for information regarding the timeline and potential FHIR reporting options for selected measures starting in 2028.
• CMS is also looking for feedback on AI-assisted primary care and annual wellness visits, including whether AI can:
• Gather information before a visit.
• Summarize medical histories.
• Identify patients needing further assessment.
• Recommend follow-up actions for clinician review.
• Create patient instructions to language and health literacy.

More on the proposed rule can be found in the accompanying press release, fact sheet and addenda, along with fact sheets specific to MSSP and QPP. Look for additional analyses from your ACC advocacy team on ACC.org/Advocacy and in upcoming issues of the ACC Advocate newsletter.

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