HCPCS codes in the rule are placeholder codes. Actual codes will be released with the Final Rule in Nov. 2026.
If you didn’t attend the webinar live, here’s a summary. And, you can always watch on demand.
https://codingintel.com/cmss-2027-proposed-medicare-physician-fee-schedule-rule/(opens in new tab)
Conversion factor
This is our second year with two conversion factors for services paid under the Physician Fee Schedule.
The proposed CF for Qualifying Professionals is $33.17 and for non-QPs is $32.84. This stems from a 2015 rule, MACRA. MACRA stipulated that Qualifying Practitioners (QPs) who didn’t participate and meet certain thresholds in alternative payment models (APM) such as Merit-based Incentive Payment System (MIPS) and MIPS Value Pathways (MVP) would see a lower update to the conversion factor then those who did.
Practice Expense Update
CMS is proposing to gradually change the method they use to develop RVUs for practice expenses. They are proposing to decrease their reliance on the AMA’s survey data.
Telehealth
Many of the pandemic-era telehealth flexibilities including geographic restrictions lifted, patients allowed to receive services from home, and an expanded list of eligible practitioners were already extended through December 31, 2027 by the Consolidated Appropriations Act, 2026. That same law pushed back the in-person visit requirement for mental health telehealth services to January 1, 2028, and continues to allow audio-only telehealth through that date.
There were no requests from the public for additions to the telehealth list. However, CMS is proposing to add new HCPCS codes (discussed below) to the telehealth list. The proposed additions include GACP1 and GACP2 (clinical staff time for advance care planning), GSMAS (voluntary group-based medical visits), GSLPP (treatment of speech, language, voice, or auditory processing disorders in patients up to age 18 or 21), and GADV1 (an E/M add-on for diagnosing and treating vaccine adverse effects). More about these new proposed HCPCS codes below. (These are placeholder codes).
CMS also proposes revisions to the telehealth critical care consultation codes, G0508 and G0509. The frequency limitations on these codes were removed in 2026, and the new proposal would drop the words “initial” and “subsequent” from the code descriptors, replacing those words with the time descriptors that match CPT® code 99291—99292. 99291 for 30-74 minutes and 99292 for each additional 30-minute increment. Keep in mind that unlike CPT®, CMS doesn’t use the midpoint rule. Need a refresher on how to tell time? (for critical care, not in general)?
https://codingintel.com/a1-critical-care-services-101/(opens in new tab)
https://codingintel.com/billing-guide-critical-care-services/(opens in new tab)
In response to a requirement in the Consolidated Appropriations Act, 2026, CMS is establishing two new telehealth modifiers effective January 1, 2027: modifier BB, for services furnished through certain virtual telehealth platforms that contract with an entity that owns the platform, and modifier BC, for telehealth services furnished “incident to” another practitioner’s service. CMS is clear that these modifiers won’t affect payment, and says further guidance on their use will be posted on the CMS website. CMS hasn’t released any specific information about this as of now.
Modifier 25
I wrote about this last month in our newsletter for all.
https://codingintel.com/modifier-25-forever-and-always/(opens in new tab)
This proposal got a lot of press. CMS is proposing to reduce payment when modifier 25 is appended to a claim involving a procedure with a 0-, 10-, or 90-day global period (an E/M service billed with a 90-day-global procedure would not use modifier 25 in the first place). Under the proposal:
The highest-valued line item (E/M or procedure) is paid at 100%.
The second and subsequent procedures are paid at 50%.
This mirrors the existing Medicare multiple-procedure payment reduction rule. CMS said it wouldn’t be appropriate to schedule services in a way that maximizes payment, since doing so creates burden and potential risk for beneficiaries. That is, don’t do an E/M today and schedule the patient to come back for the procedure in two days.
Primary Care Exception
The primary care exception currently lets a teaching physician bill for low and mid-level E/M services performed by a resident when the attending doesn’t see the patient. These are CPT® 99202–99203, 99211–99213, and the Welcome to Medicare and annual wellness visit codes (G0402, G0438, G0439). CMS is proposing to expand this exception in primary care teaching settings to cover all levels of office visits, including the higher-complexity codes 99204, 99205, 99214, and 99215.
https://codingintel.com/teaching-physician-primary-care-a2/(opens in new tab)
Teaching Physician Supervision
Under current rules, virtual supervision of a resident is only permitted when the resident, the teaching physician, and the patient are all in different locations. CMS is proposing to allow the teaching physician to report the service as long as either the resident or the teaching physician is physically in the room with the patient. This seems like a more likely scenario than all three people being in separate locations.
https://codingintel.com/teaching-physician-rules-b1/(opens in new tab)
G2211–transforming into modifiers
This is sort of like those transformer toys. G2211, is an add-on code for visit complexity tied to a patient’s ongoing, longitudinal care or single, serious condition. It can be used with office visits and home and residence services. It currently pays the same flat fee regardless of the E/M level reported, and carries a work RVU of 0.33.
CMS is proposing to eliminate G2211 and replace it with two new modifiers, MOD1 and MOD2.
MOD1 will reimburse 16% of the base fee for the E/M code billed
MOD2 will reimburse 32% of the base fee for the E/M code billed, and is reserved for practitioners participating in Medicare Shared Savings Program ACOs and Lead Model ACOs.
MOD1 Visit complexity inherent to new or established office/outpatient or home or residence evaluation and management service, 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 condition.
MOD2 Visit complexity inherent to new or established office/outpatient or home or residence evaluation and management service, associated with medical care services furnished by a participant or practitioner participating in a Medicare accountable care organization. Services must serve as the continuing focal point for all needed health care services and/or be part of ongoing care related to a patient’s single, serious condition or complex condition.
These are placeholder modifiers, not the final modifiers.
Shared Medical Appointments Get a Code
CMS is proposing to pay for shared medical appointments. These are group visits for patients with a common chronic condition, involving one “prescribing” practitioner along with other health professionals. Notably, CMS states that some practitioners are “already billing” SMAs today using existing E/M codes 99212-99215, based on medical decision-making criteria. (Editorial comment: I’ve told groups for years that the E/M codes are for seeing a single patient, not for group visits.)
Patients must have an existing clinical relationship with the practitioner or a same-specialty partner, specific beneficiary consent is required and agreement to confidentiality. CMS proposes to allow 10 participants in the group and to require the meetings to be a minimum of 60 minutes.
CMS is proposing a new code, GSMAS, for a voluntary group-based session of 2 -10 patients that combines group education, counseling, and peer support with individualized clinical assessment. It is billed once per patient, per session. (GSMAS is a placeholder code.)
GSMAS: Voluntary, group-based medical session involving multiple patients with common medical condition(s), receiving medical care in a group setting; billed and led by a physician or qualified nonphysician practitioner and may include services provided by other qualified healthcare professionals, clinical staff, or auxiliary personnel under the direction of the supervising physician or other practitioner. Session integrates group education, counseling, and peer support with individualized patient clinical assessment and care, 2-10 patients, billed once per patient, per session.
Vaccine Adverse Effects and Pediatric Speech Therapy
CMS notes that standard E/M services already capture the work of managing most vaccine reactions, but may not adequately capture the additional work involved in evaluating and managing rare, severe adverse reactions. The proposed add-on code, GADV1, would cover 15-minute increments personally performed by the physician or qualified healthcare professional, billed in addition to office and home/residence E/M codes. These are not codes for us by staff members.
GADV1: Office or other outpatient evaluation and management service(s) for the diagnosis and treatment of vaccine adverse effects, new or established patient; each 15 minutes personally performed by the physician or qualified healthcare professional (list separately in addition to CPT codes 99202, 99203, 99204, 99205, 99211, 99212, 99213, 99214, 99215, 99341, 99342, 99344, 99345, 99347, 99348, 99349, 99350
Add on code to office and home/residence services
A new code, GSLPP, is proposed for treatment of speech, language, voice, communication, and/or auditory processing disorders in patients up to age 21, reportable once per calendar day performed by a speech-language pathologist. (Placeholder code)
GSLPP Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual; for the pediatric population up to age 21
CPT® Category III Health and Well-Being Coaching Codes
CMS is proposing to recognize three existing Category III codes for health and well-being coaching:
0591T Health and well-being coaching face- to-face; individual, initial assessment, 60-90 minutes
0592T Individual, follow-up session, at least 30 minutes
0593T Health and well-being coaching, group [2 or more individuals], at least 30 minutes
CPT® code 0593T would be billed once per beneficiary in the group.
Advance Care Planning (ACP): New Staff-Time Codes
ACP is currently billed using CPT® codes 99497 and +99498, paid under the physician fee schedule for services furnished by physicians or other qualified health professionals. CMS is proposing two new HCPCS codes. GACP1 first 20 minutes of clinical staff time discussing and completing advance directive forms with the patient and/or family, under a treating practitioner’s direction and GACP2 each additional 20 minutes. These will separately recognize clinical staff spent doing this work, including when performed incident-to.
About whether the existing CPT® ACP codes may be billed by clinical staff under the supervision of the physician or NPP, CMS said this in the Proposed Rule:
“As we said in the CY 2016 FPS final rule (80 Fed. Reg. 70956), the services described by CPT® codes 99497 and 99498 are appropriately provided by physicians or using a team-based approach provided by physicians, nonphysician practitioners (NPPs) and other staff under the order and medical management of the beneficiary’s treating physician. The CPT® code descriptors describe the services as furnished by physicians or other qualified health professionals, which for Medicare purposes is consistent with allowing these codes to be billed by the physicians and NPPs whose scope of practice and Medicare benefit category include the services described by the CPT® codes and who are authorized to independently bill Medicare for those services. Therefore, only these practitioners may report CPT® codes 99497 or 99498. The ACP services
described by these codes are primarily the provenance of patients and physicians; accordingly we expect the billing physician or NPP to manage, participate and meaningfully contribute to the provision of the services in addition to providing a minimum of direct supervision. The usual PFS payment rules regarding ‘‘incident to’’ services apply, so that when the services are furnished incident to the billing physician or practitioner all applicable state law and scope of practice requirements must be met and there must be a minimum of direct supervision in addition to other incident to rules.”
CMS is specifically seeking comments for several questions. How direct supervision and incident-to billing should work, whether the CPT® codes and new HCPCS codes could be reported together if their separate time thresholds are both met, and whether the new codes should be valued using combined time or clinical-staff-only time.
New HCPCS codes proposed for clinical staff time
GACP1 Advance care planning including the explanation and discussion of advance directives such a s standard forms (with completion of such forms, when performed), first 20 minutes of clinical staff time with the patient, family member(s), surrogate directed by a treating physician or other treating qualified health care professional
GACP2 each additional 20 minutes with the patient, family member(s), surrogate directed by a treating physician or other treating qualified health care professional (List separately in addition to code for primary procedure)
CMS is specifically seeking comments on these proposed services.
Remote Physiologic and Therapeutic Monitoring: A Structural Rework
The proposal for Remote Physiologic Monitoring (RPM, an E/M-section CPT® service) and Remote Therapeutic Monitoring (RTM, from the CPT® Medicine section) is proposing a sweeping change in the rule. It follows OIG reports from 2024 and 2025 that found some vendors were cold-calling beneficiaries, failing to deliver all required service components or train patients on devices, billing without an established patient relationship, and billing for multiple monitoring devices in the same month. CMS frames the proposal as a direct response to outsourced, third-party staffing arrangements.
The proposed changes include:
- A required, separately billable initiating visit at the start of RPM/RTM services — a face-to-face or telehealth appointment with the billing practitioner that includes an explanation of the service and specific patient consent, similar to requirements for care management services.
- Extending the established-patient requirement to RTM, matching a rule that currently applies to RPM. The proposed rule doesn’t specify which codes qualify as the initiating visit, though office visits or wellness visits seem likely candidates.
- Requiring direct employment of clinical staff who perform RPM/RTM services, effectively ending the use of outsourced staffing companies. CMS argues that outsourced staff lack an established relationship with the patient and have limited interaction with the billing practice. General supervision would still be allowed, and practice-employed staff could still work remotely. The change targets third-party vendors specifically.
- Lowering the valuation of the device-supply and treatment-management codes.
And, Replacing CPT® codes with HCPCS codes for RPM and RTM entirely The current 17 separate CPT® codes for RPM and RTM would be replaced with just four new HCPCS codes:
GRPM1 RPM initial set-up and patient education
GRPM2 Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), per calendar month, including:
++ Device(s) supply with daily recording(s) or programmed alert(s) transmission.
++ 2 or more days of data transmission.
++ Treatment management services, requiring at least one real-time interactive communication with the patient/caregiver; time totaling at least 20 minutes
GRTM1 RTM initial set-up and patient education
GRTM2 Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), per calendar month, including:
++ Device(s) supply with daily recording(s) or programmed alert(s) transmission.
++ 2 or more days of data transmission.
++ Treatment management services, requiring at least one real-time interactive communication with the patient/caregiver; time totaling at least 20 minutes
This is a highlight of the coding and policy changes for 2027.
One final note. In the Proposed Rule, CMS questioned whether it was a conflict of interest to rely on code valuation from the AMA’s RUC committee.
Here are their exact words. “There has also been longstanding concern expressed over the Federal reliance on a private organization with such an obvious conflict of interest as providing information on the time and resource requirements to conduct physician services when this information may influence their own payment.” p. 306 Display Copy
“Given these longstanding concerns, we are seeking comment on a number of areas regarding the influence of the CPT® coding system and AMA process on physician payment policy as part of the Secretarial priority to Make America Healthy Again.” p. 307 Display Copy
I don’t have a dog in this race, as the saying goes, but anytime we can take 17 codes and reduce them to 4 codes, I’m all in. (RTM/RPM proposal).
Maternity Care Codes: A Coming Collision
The AMA has substantially revised the maternity care code set for CPT® 2027 and released draft pages of that section of the book in advance. The AMA has presented the topic in person and via webinar. CMS, in turn, is proposing to develop its own parallel HCPCS codes that follow the old CPT® structure. Let’s hope the commenters can nip this in the bud. Having two sets of maternity codes, one of which are HCPCS codes that match the old CPT® codes and one set that includes new and established codes? Really? Why not just give up on any OB services being paid at all in 2027.