CMS 2027 Medicare Physician Fee Schedule Proposed Rule: Key Changes Wound Care Providers Should Know
The CY 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule includes several significant proposals that could affect reimbursement, coding, documentation, and clinical workflows for wound care providers.
Key Takeaways
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Skin substitute and wound technology policies are evolving. CMS proposes to reimburse non-sheet skin substitutes applied in the office setting at the same per-square-centimeter rate as sheet products, adopt AMA RUC recommendations for skin cell suspension autografts, and establish payment for a new Category I CPT code that represents real-time fluorescence wound imaging.
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Evaluation and management payment could change significantly. CMS proposes reducing payment by 50% for the lower-valued service when a separately identifiable E/M visit is billed with a procedure, replacing HCPCS G2211 with a modifier, and transitioning all traditional MIPS reporting to MIPS Value Pathways (MVPs) by 2029.
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Operational and payment proposals extend beyond coding. The rule includes proposed reductions to 2027 physician conversion factors, restrictions on outsourcing remote monitoring services, and a broad request for stakeholder feedback on the future of the AMA CPT® coding system and physician payment methodology.
The Centers for Medicare and Medicaid Services (CMS) released the Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule.1 This publication contains proposals from CMS regarding payment policies for services performed by physicians and other qualified healthcare professionals.
The proposals outlined in this Proposed Rule are subject to a 60-day comment period during which any stakeholder can submit comments about what has been proposed. Some time after this comment period closes and CMS has had an opportunity to consider the submitted comments, the Calendar Year (CY) Medicare Physician Fee Schedule Final Rule will be released. This Final Rule, typically released the first or second week of November, will detail finalized policies that will take effect January 1, 2027. Below, those proposals most pertinent to wound care providers are outlined.
Conversion Factor
CMS proposes a CY 2027 physician fee schedule qualifying alternative payment method (APM) conversion factor of $33.1693 (would be a 1.19% reduction from CY 2026) and proposes a nonqualifying APM conversion factor of $32.8409 (would be a 1.68% reduction from CY 2026).1 These conversion factors reflect expiration of a temporary 2.5 percent update for CY 2026 included in H.R. 1, a 0.535 budget neutrality adjustment to balance proposed coding and payment policy changes, and a 0.5% increase for Qualified Participants in Advanced Alternative Payment Models under MACRA.1
E&M Services Submitted With a Procedure
CMS is proposing to reduce payment for the lesser valued service by 50% whenever an evaluation and management (E&M) code is submitted at the same time as a procedure, even if that E&M is significant in nature and separately identifiable from the procedure.1
Non-Sheet Skin Substitutes
In this Rule, CMS recognizes four relatively new G codes, HCPCS G0681–G0684, that represent “application of a premarket approval (PMA), 510(k), 361 human cells, tissues or cellular and tissue-based products (HCT/P) non-sheet form skin substitute.”2 Furthermore, CMS proposes to price these non-sheet skin substitutes at the same per-square-centimeter (cm2) rate as sheet-form skin substitutes for 2027. CMS bases this proposal on their claim that the resource costs for non-sheet skin substitutes and sheet-form skin substitutes are comparable. For non-sheet skin substitutes products, CMS states that the square centimeters of product submitted should reflect the wound surface area treated.1
Skin Cell Suspension Autograft
CMS proposes to adopt the AMA Relative Value Scale Update Committee (RUC)-recommended RVUs and direct practice expense (PE) inputs for skin cell suspension autograft services exactly as they were recommended from the RUC.1
Real-Time Florescence Wound Imaging
There will be a new Category I CPT code in the 2027 CPT code set to represent “real-time florescence wound imaging with clinical darkness to identify presence, location, load of bacteria and measure wound size, per day.”1 This exact code number has not been published yet and it is currently being referred to as “CPT 976XX.” CMS proposes a work RVU of 0.80 for this new code. CMS invites stakeholders to provide feedback on this proposed work RVU.
MIPS
CMS proposes to sunset traditional MIPS reporting in 2029 and replace traditional MIPS reporting with MIPS Value Pathways (MVPs).1
CPT® Process
CMS requests comments from stakeholders regarding the AMA’s CPT® coding system, CPT licensing, the CPT code development process, and the RUC. CMS is asking for comments regarding alleged harms associated with the AMA’s “monopoly over CPT-4 licenses” and cites concerns about reliance on a private organization with an “obvious conflict of interest” in recommending physician service values. In the Proposed Rule, CMS asks 5 questions which seek input on CPT licensing costs and effects, the role of medical necessity in code development, possible alternatives or supplements to CPT as the national physician services code set, alternative governance and valuation processes, and whether physician services could instead be paid using ICD-10-PCS or other bundled payment approaches.1
Single Serious or Complex Condition
HCPCS G2211—Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition2
Today, HCPCS G2211 may be submitted when an office or other outpatient E&M service is performed, and that E&M is:
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Part of providing all needed health care services for that patient
And/or
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Part of ongoing care related to a patient’s single, serious condition
And/or
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Part of ongoing care related to a patient’s complex condition
Today, when HCPCS G2211 is submitted, it should be added to an office or other outpatient E&M CPT code. In the CY 2027 Medicare Physician Fee Schedule Proposed Rule, CMS proposes to delete G2211 and, instead, create a modifier that could be appended to an E&M that would represent the situation described above.1
Remote Monitoring
Some wound care practitioners who provide remote monitoring enjoy outsourcing certain aspects of the monitoring outside their own practice to paid contractors. CMS is proposing to no longer allow this outsourcing of monitoring to contractors. If this proposal is finalized, only clinical staff employed by the practice would be allowed to perform this monitoring.1
Any stakeholder can submit comments on these proposals and those comments may be submitted to CMS until September 14, 2026. When submitting comments, authors should reference file code CMS-1848-P. Comments can be submitted electronically at https://www.regulations.gov/docket/CMS-2026-2377.
Comments can also be submitted using traditional mail sent to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016. Finally, comments may be submitted by express or overnight mail sent to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
Dr. Lehrman is a Board Certified Podiatrist, Certified Professional Coder, Certified Professional Medical Auditor, and Certified Evaluation and Management Coder. He operates Lehrman Consulting, LLC which provides guidance regarding coding, compliance and documentation.
References
1. Centers for Medicare & Medicaid Services. Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program. Fed Regist. 2026;91(135):43842-44557. Published July 16, 2026. Accessed July 20, 2026. https://www.federalregister.gov/documents/2026/07/16/2026-14327/medicare-and-medicaid-programs-cy-2027-payment-policies-under-the-physician-fee-schedule-and-other
2. Centers for Medicare & Medicaid Services. Healthcare Common Procedure Coding System (HCPCS) Level II Coding Procedures. Accessed July 20, 2026. https://www.cms.gov/medicare/coding/medhcpcsgeninfo/downloads/2018-11-30-hcpcs-level2-coding-procedure.pdf
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