CY 2027 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (CMS-1848-P Display)

Kristen Prince, COO of Therapy First, opposes the proposed reduction in the Medicare conversion factor for CY 2027. She argues that the reduction, combined with rising operational costs, will create a reimbursement cut that threatens the viability of independently owned outpatient physical therapy practices, particularly in rural areas.

Physician Anesthesia Services, a small anesthesia group in Colorado, opposes the proposed decrease in the 2027 anesthesia conversion factor. They argue that the current Medicare rate is unsustainable due to rising costs and workforce shortages, and they request a comparative analysis of reimbursement across physician specialties.

Go Medical Billing LLC opposes the proposed conversion factor reduction and same-day payment reductions, arguing they will create unsustainable economic conditions for small practices due to rising administrative costs and denial rates. They request that CMS publish NCCI edit rationale in machine-readable form and provide a state-level impact table for small practices regarding geographic payment variations.

The commenter, a clinic owner in South Alabama, opposes the proposed changes to pediatric speech therapy reimbursement (specifically code 92507). They argue that the proposed time breakdowns do not account for the intensive labor required for medically complex children and that reduced reimbursement rates would threaten the clinic's ability to stay in business.

A physician from an independent private gastroenterology practice opposes the proposed CY 2027 Medicare Physician Fee Schedule due to concerns that low reimbursement rates and high regulatory costs threaten the sustainability of independent practices. The commenter urges CMS to provide payment updates that reflect inflation and practice costs while preserving physician independence and patient access.

The commenter opposes the proposed 2027 Medicare Physician Fee Schedule, arguing that inadequate reimbursement rates will harm patient access and lead to practice consolidation. They specifically oppose the 50% payment reduction for modifier 25 E/M services, stating it undervalues physician work and creates unnecessary costs for patients.

A pediatric speech therapist provides feedback on the time distribution for pediatric speech therapy sessions, arguing that the proposed 5-50-5 distribution does not accurately reflect the time spent on setup, transitions, breaks, and family coordination. The commenter notes that while the 60-minute total is accurate, the breakdown of direct versus indirect tasks is incorrect based on their professional experience.

A Nurse Practitioner in Idaho opposes the proposed cuts to physician reimbursement, specifically those targeting modifier 25. The commenter argues that these changes will undermine the financial viability of independent dermatology practices, force patients to return for multiple visits, and decrease the efficiency of care.

A dermatologist in rural Wisconsin opposes the proposal to reduce payments by 50 percent for lower-valued services when a separately identifiable E/M visit is furnished on the same day as a global procedure. The commenter argues that the reduction is arbitrary, lacks empirical basis, and will negatively impact patient access and the viability of independent practices.

The commenter, representing a small independent dermatology practice, opposes the proposed cuts to Modifier 25 reimbursement. They argue that these cuts will lead to fragmented care, increased costs, and greater burdens on Medicare patients by forcing multiple visits for issues that could be managed in a single appointment.