On Tuesday, July 14, the Centers for Medicare & Medicaid Services (CMS) released the CY 2027 Medicare Physician Fee Schedule (MPFS) proposed rule and fact sheet. The following is a high-level summary of the policies that will affect AUA members. AUA staff are reviewing the proposed rule, and will be submitting a comment letter to CMS, ahead of the September 14 comment deadline.

Conversion Factor

For the second year, there are two separate conversion factors: one for qualifying advanced APMs, and the other for those not in qualifying APMs: 

• Qualifying APM Conversion Factor: $33.17, a decrease of 1.19% 
• Non-qualifying APM Conversion Factor: $32.84, a decrease of 1.68% 

Decreases of the two conversation factors are due to Congress only providing a one-year conversion factor increase of 2.5% for CY 2026, therefore current law requires a 2.5% reduction to Medicare payments compared to CY 2026.

Impact to the Specialty of Urology

CMS estimates that, if implemented, the policies in the rule will have a net impact of -2% in total Medicare charges for urology. The negative impact is the result of several proposed changes in the rule, and expiration of the +2.5% payment adjustment implemented in 2026. Some of the policies that affect overall Medicare payments to urology include the changes in payment policy for same-day E/M visits and global surgical periods, phasing out certain historical practice expense specialty data, and the proposed deletion of code G2211 which will be replaced by a modifier to capture the work of complex patient care associated with an E/M visit. These policies, if finalized continue the trend of downward payment pressure on physicians and their practices, even as operating costs continue to increase.

Note that impact of proposed policies on group practices and individual physicians varies based on practice type, payer type, mix of patients and the types of services provided to those patients.

CMS Accepts Nearly All RUC Recommendations for Urology Services

The AUA continues to serve our members by participating in the AMA RUC process and advocating for relative value units (RVUs) that reflect the work of urologists. By participating in the RUC survey process, the AUA advocates for work and practice expense values for new and revised CPT codes. CMS proposes to accept the AMA RUC recommended values for all the services recently surveyed by the AUA except for one code associated with the revised prostate biopsy services. AUA RUC and CPT advisors and staff were instrumental in maintaining the values of the revised prostate biopsy service codes, and the AUA is pleased that CMS has accepted the work values as proposed by the RUC.

Appendix A lists new and resurveyed codes with RUC recommended values and CMS proposed values for services performed by urologists.

Global Surgical Package Revisions

As with prior years, CMS continues to examine payment associated with the concept of the global surgical package. The global surgical package, also known as the global period or simply the globals, is a billing and payment concept used by Medicare to provide a single, flat payment made for all care associated with a surgical procedure which includes pre-operative and post-operative E/M visits, and payment for the surgery.

CMS proposes to reduce payment when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as the procedure included in a 0, 10, or 90-day global. The most expensive service (either surgical or E/M visit) would be paid at 100% and all other surgical procedure(s) or E/M visit(s) furnished on the same day would be paid at 50%. This policy will affect physicians who provide an E/M service, coupled with a same day procedure.

CMS is also proposing to pause the data collection required under section 523 of MACRA and to revise the process to improve global surgical service valuation and payment accuracy. The agency believes that the current data collection on global services is burdensome to providers and is seeking comment on ways to better collect data to more accurately value payment for global surgical services.

Changes to Additional Payment for Complex Patient Care – HCPCS Code G2211

The agency proposes to delete code G2211 (Visit complexity inherent to evaluation and management associated with medical care services) and create a modifier to take its place.[1] The modifier, MOD1, will have the exact same descriptor as G2211, and should be reported and billed in the same way as the G-code. The modifier when appended to an appropriate E/M code will be reimbursed at 16% of the value of the billed E/M code.

Remote Monitoring Services: Changes to Billing Requirements

Citing the need for appropriate use and billing of remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services, CMS proposes that practitioners who provide RTM and RPM services must first conduct a separately reportable initiating visit prior to starting RTM and RPM.[2] The initiating visit may be conducted either in-person or via telehealth and the use of RTM and RPM must be discussed with the patient.

Additionally, citing a recent Office of Inspector General (OIG) report which indicated a need for additional oversight for remote monitoring services, CMS proposes that Medicare payment for RTM and RPM services will only be made when the services are provided by clinical staff employed by the physician or practice. That is, to count the time spent by clinical staff when providing RTM or RPM services, the clinical staff cannot be employed by a third party contractor, the clinical staff must be a “direct employee of the practitioner or practitioner’s practice.” CMS clarifies that the clinical staff do not have to be physically located within the practice, nor does the beneficiary need to be on-site. CMS believes that third party outsourced RTM and RPM  services leads to fragmented care particularly given the third party has little to no connection to the patient, no is there appropriate oversight and supervision of the provision of the services. Of note, CMS is seeking comment on how often third parties provide RTM and RPM services, and whether the proposal, if finalized, may affect Medicare beneficiary access to these services.

Finally, to reduce administrative burden, improve care coordination and reduce fraud, waste and abuse, CMS seeks comment on a policy option that would create four remote monitoring HCPCS codes to replace the seventeen RTM and RPM CPT codes for purposes of Medicare billing and payment. CMS has not proposed this policy, and is only seeking comment.

CMS Seeks Comment on AMA’s Current Procedural Terminology (CPT)

The agency takes aim again, at the AMA’s CPT and RUC processes, and is seeking comment on the federal government’s reliance on the use of CPT codes in its programs. Once again calling out the “obvious conflict of interest of providing information on the time and resource requirements to conduct physician services when this information may influence their own payment.” Therefore, CMS seeks comment on several topics including,

• What, if any, evidence is there for CMS to consider regarding the harms or challenges associated with AMA’s monopoly over CPT-4 licenses for health care entities.
• What objective alternatives exist, or could be developed, to maintain a more objective process to the current AMA CPT and RUC committee processes? How would these alternatives support or inhibit innovation?

Appendix A: RUC Recommended and CMS Proposed Work RVUs for CY 2027

[1] HCPCS code G2211 full description: 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.

[2] CPT Codes 98975, 98976, 98977, 98978, 98980, 98981, 98984, 98985, 98986, 98979, 99091, 99453, 99454, 99457, 99458, 99473, 99474, 99445, and 99470 are used to report RTM and RPM services.