Article
The proposal on the table
CMS released the CY 2027 physician fee schedule proposed rule on July 14, and the comment period ended September 14. The conversion factor would fall 1.68% for clinicians who are not qualifying participants in advanced alternative payment models and 1.19% for those who are. The cut reflects small statutory updates and a 0.53% adjustment tied to work value changes, outweighed by the expiration of the one-year 2.5% increase Congress provided for 2026.
Several other proposals matter for hospitals with large employed groups:
- Practice expense reform: CMS wants to rely less on specialty-specific practice expense survey data and to change how indirect costs are calculated.
- Same-day visits: An office or outpatient evaluation and management visit billed on the same day as a global procedure would be paid at half the usual rate.
- Remote monitoring: The rule proposes changes to remote monitoring services.
- Accountable care: Shared Savings Program changes aim to add savings in two-sided risk tracks and attract new ACOs.
Where the AHA pushed back
In its September 14 letter, the American Hospital Association opposed the conversion factor cut and asked CMS to work with Congress on a more adequate update. It urged the agency not to finalize the indirect practice expense changes until it publishes a more detailed impact analysis, and it pressed for repeal of the practice expense site-of-service differential between facility and non-facility settings. It also asked CMS to drop the same-day visit reduction, arguing it would fragment care, and to hold off on the remote monitoring changes, which it said could disrupt patients’ access.
The association backed the Shared Savings Program proposals, including guardrails on the prospective benchmark trend, a higher shared savings rate in the top level of the BASIC track and a larger prior savings adjustment. It said these would ease the benchmark ratchet that discourages participation.
What to do before the final rule
- Budget conservatively: Plan 2027 professional revenue on the proposed conversion factor, and treat any congressional relief as upside.
- Run the same-day test: Have revenue cycle pull a year of claims with visits on the same day as global procedures to size the exposure by specialty.
- Review monitoring programs: Inventory remote monitoring volume and revenue so you can adjust quickly once the final policy is known.
- Revisit ACO plans: If the benchmark changes are finalized, the economics of joining or moving up a risk track may improve.
Archive entry for Sep 15, 2026, added Nov. 11, 2026.