Action Steps Following the Proposed 2027 Medicare Physician Fee Schedule

July 24th, 2026

By: Laura Manser, CPC, CPCO, CDEO, CIRCC, CPMA, CEMC, RCC, Director of Provider Education 

On July 14, CMS released the proposed 2027 Medicare Physician Fee Schedule. In this article, originally published in our Navigator newsletter, Director of Provider Education Laura Manser shares practical guidance to help radiology practices move from understanding the MPFS to preparing for its proposed implications.

For more information on the details of the MPFS, review the summary on our website.

Run your own numbers instead of using the national ones.

Pull your top 25 to 50 CPT codes by Medicare volume, apply the proposed 2027 RVUs from the CMS addenda, compare to your 2026 allowables. The published +2% is a national aggregate and will not match what your practice sees.

Confirm which conversion factor applies to you.

There are two now. Verify APM participation status rather than assuming; the difference is about half a point across your whole Medicare book.

Model professional and technical separately.

Given the practice expense proposals, they will not move together. If you bill both, run them as two scenarios.

Audit your component billing before you model anything.

CMS is changing how professional, technical, and global services are valued. A group that does not know its own component split accurately cannot model the rule or bill correctly under it. Modifier 26 and TC assignment is the place to start, especially if you have changed a hospital contract, added a site, or migrated PACS or RIS since your last review.

Look at IR documentation separately.

The projected +3% only materializes where the record supports the codes carrying it.

Do not forget the contracts.

A large share of commercial radiology contracts are priced as a percentage of the Medicare fee schedule, which means a Medicare cut propagates automatically into revenue well outside your Medicare book. Inventory those. Anything renegotiating in 2027 should be repriced against the final conversion factor, and where you have leverage, push to index to a fixed fee schedule year or a fixed dollar amount rather than a floating percentage of Medicare.

Start quality capture now, not in January.

Three diagnostic radiology measures are proposed as core measures for 2027: #145, #360, and #405. Practices that wait until the performance year begins to build capture workflows lose a quarter of data they cannot get back. Separately, MVPs are proposed to become the only MIPS reporting option beginning with the 2029 performance period. Three years is enough runway to report voluntarily and find the registry problems while the stakes are low. It is not enough if the work starts in 2028.

Comment by September 14, and comment where CMS can actually move.

The conversion factor is set by statute; CMS cannot change it in this rule no matter how many letters it receives. The practice expense methodology is discretionary and genuinely in play. That is where practice comments have leverage.

Comments get read. In the 2026 cycle, detailed comments from IR stakeholders led CMS to revise supply pricing inputs and finalize a new angiography supply pack. What works is specificity: code-level time and staffing data from your own operations, actual invoices where practice expense inputs are at issue, real patient access consequences with volumes and geography, and a workable alternative rather than only an objection. Three real data points from your own practice beat five pages of argument.

Support your society’s letter rather than duplicating it. ACR, SIR, and RBMA will all file, and a practice comment that supplies operational data behind a society position is worth more than one that restates it. On the legislative side, H.R. 6160 would tie the annual update to the MEI, and the most effective thing an individual practice can do is tell its own delegation how many people it employs, how many Medicare patients it serves, in which counties, and what specifically stops working at the proposed rates. No association can supply that for you.

Treat the duplicate imaging RFI as advance notice.

That is where utilization management policy starts. Groups with solid prior-study retrieval and outside-image integration are fine. Groups without it now know what is coming.