Medicare's 2027 Fee Schedule Would Cut the Conversion Factor and Turn G2211 Into a Percentage Modifier. Model It Before the Final Rule.
CMS proposed 2027 conversion factors down 1.19 percent and 1.68 percent, a 16 percent modifier in place of G2211 and half payment for some same-day visits billed with modifier -25. Comments closed Sept. 14, and the final rule is still pending.
Idea in Brief
The News
CMS's proposed 2027 fee schedule would set conversion factors of $33.1693 for qualifying APM participants and $32.8409 for everyone else, replace G2211 with a 16 percent modifier and pay some same-day services at 50 percent.
What Changes
The one-year 2.5 percent increase for 2026 expires, G2211 moves from a flat add-on to a share of the base E/M payment, and on a same-day modifier -25 claim only the highest-paid service would be paid in full.
Why It Matters
Billing offices can model all three proposals now from public data and should know what to check when the final rule posts.
On July 14, the Centers for Medicare and Medicaid Services released its proposed 2027 Medicare physician fee schedule. The comment period closed Sept. 14, with 44,346 comments filed at Regulations.gov, according to the Federal Register listing. As of Oct. 11, no final rule had been published, so every figure below is a proposal that can still change.
Three proposals will move revenue in most offices: a lower conversion factor, a percentage modifier in place of G2211, and half payment for some same-day services billed with modifier -25. The data to model all three is already public.
The conversion factor
The proposed rule would set the 2027 conversion factor at $33.1693 for clinicians who are qualifying alternative payment model participants and $32.8409 for everyone else. Against the 2026 factors of $33.5675 and $33.4009 set in the 2026 final rule, those are declines of 1.19 percent and 1.68 percent.
The cut comes from the expiration of a one-year, 2.5 percent increase that Congress provided for 2026 only. The CMS fact sheet says the 2027 statutory updates are 0.75 percent for qualifying APM participants and 0.25 percent for others, plus a 0.53 percent adjustment for proposed changes in work RVUs, and that current law requires a 2.5 percent reduction from 2026.
The conversion factor is the one change every practice shares. The G2211 and modifier -25 proposals depend on what you bill and how.
G2211 becomes a modifier
CMS proposes to retire the add-on code and replace it with a modifier that raises payment for the base office or outpatient E/M visit by 16 percent. The modifier is a placeholder, called MOD1 in the rule, and would receive a two-digit HCPCS modifier if finalized. It would be billed in the same circumstances as G2211 is now, and because it sits on the E/M line, it would not need a separate claim line, per the proposed rule. CMS derived the 16 percent from a utilization-weighted average of what G2211 adds to E/M codes, adjusted for budget neutrality.
The change shifts value toward higher-level visits. The rule says G2211 carries 0.52 total non-facility relative value units, a 29 percent increase on a 99212 (1.78 units) and 9 percent on a 99215 (5.76 units). By our arithmetic on those values, 16 percent is about 0.28 units on a 99212 and about 0.92 on a 99215.
A second modifier, MOD2, would add 32 percent for clinicians in Shared Savings Program accountable care organizations and for participant providers in the Long-term Enhanced ACO Design (LEAD) Model. Per the CMS fact sheet, its use would be voluntary, it could be billed for all beneficiaries these clinicians see, and claims carrying it would be included in beneficiary assignment calculations.
CMS proposes to keep the current limits on G2211 with modifier -25 for both modifiers: payable on the same day as an annual wellness visit, vaccine administration or a Part B preventive service. The American College of Cardiology, which submitted comments on Sept. 10, offered alternatives to the modifier approach, noting that modifier payments do not carry relative value units and could reduce physician compensation.
Clinical Pearls
- The proposed 2027 conversion factors are $33.1693 for qualifying APM participants and $32.8409 for all other clinicians.
- The proposed declines of 1.19 percent and 1.68 percent follow the expiration of the one-year 2.5 percent increase for 2026.
- The G2211 replacement modifier would add 16 percent to the base office or outpatient E/M payment, and a 32 percent version would be available to Shared Savings Program ACO clinicians and LEAD Model participant providers.
- G2211 is currently worth 0.52 total non-facility RVUs, a 29 percent increase on a 99212 and 9 percent on a 99215.
- On a day with a separately identifiable office E/M visit and a 0-, 10- or 90-day global procedure, only the highest-paid service would be paid at 100 percent and the rest at 50 percent.
- CMS expects the largest losses from the same-day proposal in otolaryngology, dermatology and podiatry.
Half payment for same-day services
When the same physician or group bills a separately identifiable office or outpatient E/M visit with modifier -25 on the same day as a 0-, 10- or 90-day global procedure, the highest-paid service would be paid at 100 percent and every other service that day at 50 percent. In the rule's example, a 99212 with two lesion shavings pays the higher-valued shaving in full, while the other shaving and the 99212 are cut in half. The proposed rule says the largest negative impact would fall on otolaryngology, dermatology and podiatry, with smaller effects on hand surgery, physician assistants, and colon and rectal surgery. Most other specialties would see a small increase from redistributed values.
This is not certain to survive. CMS acknowledges that a similar proposal in the 2019 rule was not finalized. It also asks whether 25 percent would be a better reduction, whether the policy should reach inpatient E/M visits, and how it should apply to same-day visits with intravitreal injections. The ACC has urged CMS not to implement it.
What to model now
Start with claims. Flag every office E/M billed with -25 beside a 0-, 10- or 90-day procedure over the past 12 months, then reprice each of those days at 100 percent for the highest-paid service and 50 percent for the rest, using the RVUs in the addenda that CMS posted with the proposed rule. Run G2211 by E/M level, comparing the current flat payment with 16 percent of the base code. Set the baseline at the proposed conversion factors after confirming which clinicians are qualifying APM participants, since that status determines which factor applies.
ACO participants should model MOD2 separately, including its effect on assignment. The rule would also phase the Indirect Practice Cost Index out of practice expense calculations over two years and cap year-to-year changes in a service's practice expense RVUs at 5 percent. Those changes redistribute payment by specialty and belong in the same model. Groups already reviewing their 2025 MIPS feedback can fold the payment adjustment into the same 2027 forecast.
What to check in the final rule
CMS released the past three final rules between Oct. 31 and Nov. 2; the 2026 rule came out Oct. 31, 2025, and was published in the Federal Register on Nov. 5. Calendar year 2027 begins Jan. 1, so the final numbers will leave billing offices about two months.
When it posts, check four items in order: the final conversion factors; whether the same-day reduction was finalized, at what percentage and for which visit types; the assigned modifier characters and effective date for MOD1 and MOD2; and the specialty impact table. Then confirm with your practice management vendor and Medicare Administrative Contractor that claims can carry the new modifiers before Jan. 1. For a refresher on where those items sit in the document, see how to read the fee schedule.
Reported, fact-checked and edited by The Script Pad's editorial staff.
This article is for professional education and does not replace clinical judgment. Treatment decisions should be based on the individual patient and current guidelines.
