October 15th, 2026
The headline from the proposed 2027 Medicare Physician Fee Schedule looks encouraging for radiology.
CMS estimates an overall 2% positive impact for diagnostic radiology and 3% for interventional radiology under the proposed rule. But those percentages are specialty-wide estimates. They do not tell an individual practice what will happen to its Medicare revenue.
That distinction matters more this year.
In comments submitted September 11, the American College of Radiology raised concerns about proposed changes to CMS’s practice-expense methodology and asked CMS for more transparency at the CPT-code level. ACR specifically identified a proposed practice-expense RVU of zero for diagnostic digital breast tomosynthesis as something it believes is an error.
For practice leaders, the takeaway is straightforward: Don’t put 2% into the 2027 budget and call the Medicare analysis finished.
Your practice doesn’t have an average Medicare book of business.
Every radiology group has its own combination of modalities, CPT codes, sites of service, payer mix and physician work.
A breast-imaging-heavy practice will experience a fee schedule differently from a hospital-based diagnostic group. An interventional practice has a different mix again. Even two diagnostic groups with similar annual RVUs can have different financial results if one performs substantially more CT and MR and the other has a larger share of radiography, ultrasound or mammography.
That means the useful question isn’t, “What is Medicare doing to radiology?”
The question is “What is Medicare doing to the services we actually provide?”
This article outlines a series of steps your practice can take to help identify your 2027 Medicare impact.
1. Start with your own utilization.
Pull the most recent 12 months of Medicare volume by CPT code. Apply the proposed 2027 allowed amount to that same service mix. Then compare the result with what those services would produce under the current fee schedule.
That creates a much more meaningful starting point than the specialty-wide percentage.
2. Separate volume from rate.
This sounds basic, but it is easy for the two to get mixed together.
Suppose Medicare revenue grows next year by 4%.
That does not necessarily mean reimbursement improved 4%. Volume may have increased 6% while payment per service declined.
The opposite can happen too. For budgeting and contracting purposes, practices should separate:
- Rate effect: What would happen if you performed exactly the same services next year at the new Medicare rates?
- Volume effect: What revenue change is expected from performing more or fewer services?
- Mix effect: Are you performing a different combination of studies or procedures?
Without separating those three, leadership can misread what is actually happening in the business.
3. Look below the total.
After calculating the overall impact, find the CPT codes creating the change.
A practice may discover that the aggregate result is close to neutral while several important services move considerably.
That matters when those services are concentrated in a particular part of the practice.
A reduction affecting breast imaging, for example, is different from one spread evenly across hundreds of codes. The same is true for interventional procedures that require significant physician time, supplies or clinical infrastructure.
For the highest-volume and highest-revenue codes, calculate:
- Annual volume
- Current Medicare allowed amount
- Proposed 2027 allowed amount
- Dollar change per service
- Annualized revenue effect
- Physician work associated with the service
- Direct costs when the practice bears them
Then look at the result by modality and service line. The goal is to see where a payment change actually lands.
4. Use Medicare as a signal.
There is another reason this analysis matters.
Commercial contracts are frequently tied directly or indirectly to Medicare. Some pay a percentage of the Medicare Physician Fee Schedule. Others use proprietary fee schedules that still move in relation to Medicare benchmarks.
A Medicare change can therefore have consequences beyond Medicare.
Your RCM partner should be able to identify contracts using Medicare-based reimbursement and help determine which year’s fee schedule controls the rate.
“120% of Medicare” tells you very little unless you also know 120% of which Medicare schedule, updated when, with what carve-outs and under what methodology.
That becomes particularly important when CMS changes individual code values.
5. Don’t budget from the headline.
CMS’s 2027 Physician Fee Schedule is still proposed, and the comment period closed September 14. The final rule will determine what ultimately takes effect.
That is a reason to model scenarios, rather than wait.
Run the proposed schedule now. Update the model when the final rule arrives. Then use your actual volume rather than CMS’s specialty average to build the 2027 budget.
One more calculation is worth doing.
Identify the ten CPT codes responsible for the greatest amount of Medicare professional revenue in your practice.
Then ask:
What happens to those ten codes under the proposed 2027 fee schedule, and how much of our total Medicare revenue is exposed to them?
A 2% increase for radiology may ultimately be good news.
Your practice should know whether it is your 2%.