CMS issued the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, 2026. Comments are due September 14, 2026. Nothing in this section is in effect yet. Do not change 2026 claim edits to match it.
What the proposal actually says:
Conversion factors. The one-year +2.50% CY 2026 bump expires. CMS proposes a qualifying APM (QP) conversion factor of $33.17 (−1.19% from $33.57) and a non-QP factor of $32.84 (−1.68% from $33.40).
G2211 becomes modifiers. The office/outpatient E/M complexity add-on would be deleted as a standalone code. Placeholder MOD1 would add 16% to the associated E/M. Placeholder MOD2 (Shared Savings ACO or LEAD Model participant providers only) would add 32%, and CMS says those claims would feed assignment and benchmark calculations. Keep billing G2211 as an add-on through December 31, 2026.
Same-day E/M plus a global procedure. When the same physician or same practice bills a separately identifiable office/outpatient E/M on the same day as a 0-, 10-, or 90-day global procedure, CMS proposes to pay the most expensive service at 100% and every other surgical procedure or E/M that day at 50%. This is the line urology, radiation, and medical oncology should model before it is finalized. It is aimed at modifier −25 overlap, not at “stop billing E/M.”
Radiation is on the 2027 valuation list again. CMS posted CY 2027 PFS Proposed Rule Proxy Inputs for Radiation Services and Proton Beam Services (Updated 07/21/2026) on the CMS-1848-P downloads page. If you own a linear accelerator, download that file before you comment.
Behavioral health. CMS proposes to fold smoking/tobacco cessation (99406–99407) and SBIRT (G2011, G0396, G0397) into the final year of the four-year timed behavioral health work-RVU transition, and to create separate coding for shared medical appointments.
File comments at regulations.gov, file code CMS-1848-P. Silence on G2211, the 50% same-day policy, or radiation PE is how those policies become 2027 reality.
Effective January 1, 2026, CMS deleted HCPCS G6001–G6017. CPT 77385, 77386, and 77014 are deleted. All megavoltage external-beam delivery is now:
Technique no longer drives the code. IMRT is not Level 3. ASTRO’s Winter 2026 ASTROnews is explicit: a second isocenter is a plan-directed shift to additional treatment volumes after image verification, not “two anatomical sites.”
Image guidance technical services are bundled into 77402/77407/77412. ASTRO: 77387 is professional only. ASCO: the professional component of IGRT is consolidated into 77387. Do not send 77387-TC with these delivery codes for Medicare.
This is not a January problem that has since settled. ASCO (April 7, 2026), citing ASTRO’s national survey:
What to put in the chart and the prior-auth packet for 77412
Bill 77412 only when the fraction actually meets a Level 3 descriptor. If the justification is active motion management, document intrafraction localization or tracking (system used, how the target or OAR is monitored during the breathing cycle, and how that changes beam delivery). “DIBH” as a one-word indication is not a descriptor. If the justification is multiple isocenters, document the plan shifts, not the number of anatomic sites.
Non-excepted off-campus departments: CMS MLN MM14361 says bill 77402 / 77407 / 77412 with modifier PN. Do not resurrect G6001–G6017.
The CMS WISeR (Wasteful and Inappropriate Service Reduction) Model is active in six states, including Washington, from January 1, 2026 through December 31, 2031. Washington’s model participant is Virtix Health, MAC Noridian JF. The others are Texas, New Jersey, Oklahoma, Ohio, and Arizona.
WISeR does not change Medicare coverage or payment amounts. For the selected items and services, Original Medicare providers in those states submit a prior authorization request or the claim goes to post-service, pre-payment review. It does not apply to Medicare Advantage.
CMS’s public examples of selected services include skin and tissue substitutes, implantation of electrical nerve stimulators, and knee arthroscopy for knee osteoarthritis. Do not guess the rest of the list from a recap. Use CMS’s WISeR Provider and Supplier Operational Guide (PDF) Appendix A as the claim-edit source. Radiation treatment delivery is not on the CMS select-service examples.
If you implant sacral-nerve or other electrical stimulators, apply skin substitutes, or schedule those listed procedures for Original Medicare patients in Washington, build the WISeR flag before the case is on the schedule. A missing prior-auth unique tracking number is a payment delay, not a coding debate.
This part is not proposed. It has been payable since January 1, 2026.
CMS MLN909432 (January 2026) added three optional, not time-based add-on HCPCS codes when you furnish CoCM or general BHI in the same month as Advanced Primary Care Management:
You must bill an APCM base code (G0556, G0557, or G0558) in the same month. CoCM still requires the care-manager / psychiatric-consultant / treating-practitioner model. CMS says treating practitioners may be in specialties other than primary care, including oncology. Consent may be verbal; it must be in the record.
Do not double-bill time-based CoCM (99492–99494, G2214) or general BHI (99484 / G0323) in the same month as the APCM add-ons for the same patient. The 2027 proposed rule would revalue several of these codes. That is a comment issue, not a 2026 billing change.
Virtual direct supervision is permanent. For incident-to services under 42 CFR 410.26 (and listed diagnostic-test and rehab services), the supervising practitioner may be immediately available via real-time audio and visual telecommunications. Audio-only does not meet the definition. Services with global surgery indicator 010 or 090 are carved out.
Excepted off-campus drug administration is site-neutral. For CY 2026, CMS pays the Physician Fee Schedule equivalent rate, not full OPPS, for codes assigned to the drug-administration APCs when furnished in an excepted off-campus provider-based department. CMS estimated a $290 million OPPS spending reduction. If 96413 from an excepted off-campus department pays less than last year’s OPPS rate, check the PO modifier and the site of service before you treat it as an underpayment.
Separately, CMS clarified that units of selected drugs sold at Maximum Fair Price are included in ASP as of January 1, 2026. When payment is MFP-based, the Part B Drug Payment Limit File displays the MFP-based limit. Use that file; do not overlay a homemade ASP+6%.
This briefing is operational, not legal advice. Payer edits still vary. Bill from the CPT book, CMS Addendum B, and the WISeR Operational Guide, not from a recap.
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