For independent physician practices, changes to the Medicare Physician Fee Schedule can quickly affect revenue projections, staffing decisions, technology investments, and long-term planning. Practices that operate with tighter margins or a significant Medicare patient base may feel those changes more directly than larger health systems.

The Centers for Medicare & Medicaid Services (CMS) released its proposed 2027 Medicare Physician Fee Schedule in July. If finalized, the changes would generally take effect January 1, 2027. CMS is accepting public comments on the proposed rule through September 14, 2026. While the final rule could look different, several proposals deserve particular attention as independent practices prepare budgets and operating plans for the year ahead.

Key Proposed Changes for Independent Practices

Several of CMS’s proposals could have a direct effect on independent practices, particularly when it comes to Medicare reimbursement, staffing, and reporting. While the impact will vary by practice, the following changes are among the most important to watch.

Payment Rates and Same-Day Services

CMS has proposed a 2027 conversion factor of $33.17 for qualifying Alternative Payment Model participants, down 1.19% from 2026, and $32.84 for other clinicians, down 1.68%.

For independent practices with significant Medicare volume, even modest rate changes can affect revenue projections. Because the effect will differ from one practice to another, it may be helpful to model 2027 reimbursement using the services that account for the largest share of Medicare revenue.

CMS is also proposing reduced payment when separately identifiable office or outpatient evaluation and management (E/M) visits and procedures with 0-, 10-, or 90-day global periods are provided on the same day. Under the proposal, the highest-paid service would be reimbursed at 100%, while other applicable services would generally be paid at 50%. Independent specialty practices that frequently bill these combinations should review historical claims data to estimate the potential impact.

G2211 and the Continued Shift Toward Value-Based Care

CMS is proposing to replace the existing G2211 E/M visit complexity add-on code with a modifier that would increase payment for the associated E/M service by 16%. Certain clinicians participating in a Medicare Shared Savings Program ACO or the Long-term Enhanced ACO Design Model could qualify for a separate modifier increasing payment by 32%, subject to proposed requirements.

For independent primary care and specialty practices providing ongoing care to patients with complex or chronic conditions, these changes could affect both coding strategy and the financial considerations around value-based participation.

CMS is also proposing to increase the Medicare Shared Savings Program’s BASIC Track Level E shared savings rate from 50% to 60% and sunset traditional MIPS after the 2028 performance year, moving clinicians toward MIPS Value Pathways (MVPs) or other available reporting approaches.

Together, these proposals give independent practices another reason to consider whether they are prepared for Medicare’s continued shift toward value-based reimbursement.

Remote Monitoring Programs Could Face Operational Changes

Independent practices using remote physiologic monitoring (RPM) or remote therapeutic monitoring (RTM) should pay particular attention to proposed staffing and billing changes.

CMS is proposing to require a separately reportable initiating visit when RPM or RTM begins, limit RTM to established patients, and require clinical staff performing RPM or RTM services to be employed by the practice rather than contractors for the services to qualify for payment.

If finalized, these changes could significantly affect practices that rely on third-party vendors for remote monitoring. Some may need to rethink how those services are staffed and whether their current model still makes financial sense.

Practice Expense Changes Could Affect Specialties Differently

CMS is also proposing changes to how practice expenses are reflected in Medicare payment rates, moving further away from older specialty-specific data and toward more current cost information.

The impact could vary substantially by specialty and service. Independent practices, which directly absorb many operating costs, should look beyond the overall conversion factor and consider how changes to practice expense relative value units could affect the services that account for a meaningful share of Medicare revenue.

Certain Specialists Could Face Mandatory Performance-Based Adjustments

Some independent specialists may also be affected by CMS’s Ambulatory Specialty Model (ASM), a mandatory model scheduled to begin January 1, 2027.

The model applies to qualifying physicians treating heart failure or low back pain in selected geographic areas. Participants would be evaluated on factors including quality, cost, improvement activities, and interoperability, with performance affecting future Medicare Part B payments.

Practices in these specialties should confirm whether their physicians are included and consider whether their current systems are ready for the added reporting and performance requirements.

What Independent Practices Can Do Now

Independent practices do not need to wait for the final rule to start assessing where these proposals could have the greatest effect. Reviewing expected Medicare reimbursement and identifying any services or payment models that may require changes can provide a clearer picture of what to prepare for.

The final rule may differ, but early preparation can make it easier for practices to respond once CMS finalizes the 2027 Physician Fee Schedule. Contact your CRI advisor to discuss how the proposed changes could affect your practice’s financial planning and operations.