CodeCast | Medical Billing and Coding Insights
Aug 11, 2026 · 14 min · 9 segments
What are we anticipating for 2027 in the MPFS? This week Terry gives us a rundown on what to expect, how to respond before the comment period ends, and what needs to happen to strengthen our private…
Terry FletcherHost
Okay, so what are we looking at for the fee schedule? And this is a really big deal because as you know, we actually have two fee schedules.

We have one that's called APM physicians, and that's the alternative payment model, and then non-APM physicians, which is about eighty-eight percent of us.

And unfortunately, they are looking to drop it by one point seven percent, which makes me extremely mad.

The reason is, is because they are raising some of the RVUs, so the conversion factor is what is going to drop, but the RVUs are supposed to increase, so that's the value of each individual co-- billable code.

So they told us in January that our, uh, non-Q APM conversion factor was thirty-three point forty-two.

Well, then you found out on, uh, January fourth it was actually thirty-three point forty-- well, actually thirty-three point four zero zero nine.

Don't, you know, give us this and then say we're taking a couple more pennies.

And then what they're proposing for twenty twenty-seven, again for the non-APM quali-- uh, conversion factor, is thirty-two point eighty-four oh nine, so that's about a one point seven change.

And then with, um, with the qualifying, um, APM CF, they're getting thirty-three point five six right now, and theirs is also going down one point two percent to thirty-three point one six nine three.

So anesthesia's looking at a one point four percent change d- uh, decrease, and so is qualifying APM for anesthesia as well.

Remember, these proposed changes are not final, and you have a responsibility to really take a look at, you know, what they put out there and say, "Wait a minute, this doesn't really work for us." And you can, uh, comment, um, at the cms.org website, and it really...

Or I'm sorry, cms.gov website, and it'll give you some insight, and they do listen to everybody.

They don't always do what you want, but they do have to take into account everything that is, uh, said during the comment period.

Now, there's another thing on facility-based specialists, and this might apply to any listeners who, uh, your physicians are a hospital group, either employed by the hospital or an independent clinician, uh, that works at the hospital, but basically you're the, you're actually in the hospital.

And those are basically ER, um, groups and some hospitalist medicine clin-clinicians that fifty percent of hospitalists actually are independent providers, and seventy-five percent of emergency medicine clinicians are also independent providers.

And people think they actually are employees of the hospital, which they're not.

Well, when you look at indirect practice expense allocation and how they get paid, you're looking-- the proposed fee schedule actually takes money away from physicians who work in the hospital because they're not dealing with the practice expense portion of the RVU that's considered part of the facility-based, uh, expense.


And what they did is they put in an EO twelve eighty, uh, six six, EO two one two eight six six.

And just take a look, you can Google it, and they wanna have some kind of modifier that shows when there is a provider that, yes, works in a facility full-time, but they are an independent physician, uh, which means that, you know, they are also taking on that practice expense that, I don't know, sometimes the fee schedule doesn't really allow for if the location is reflective of being in a facility working instead of in an office space.

Okay, so what are we looking at for the fee schedule? And this is a really big deal because as you know, we actually have two fee schedules.

We have one that's called APM physicians, and that's the alternative payment model, and then non-APM physicians, which is about eighty-eight percent of us.

And unfortunately, they are looking to drop it by one point seven percent, which makes me extremely mad.

The reason is, is because they are raising some of the RVUs, so the conversion factor is what is going to drop, but the RVUs are supposed to increase, so that's the value of each individual co-- billable code.

So they told us in January that our, uh, non-Q APM conversion factor was thirty-three point forty-two.

Well, then you found out on, uh, January fourth it was actually thirty-three point forty-- well, actually thirty-three point four zero zero nine.

Don't, you know, give us this and then say we're taking a couple more pennies.

And then what they're proposing for twenty twenty-seven, again for the non-APM quali-- uh, conversion factor, is thirty-two point eighty-four oh nine, so that's about a one point seven change.

And then with, um, with the qualifying, um, APM CF, they're getting thirty-three point five six right now, and theirs is also going down one point two percent to thirty-three point one six nine three.

So anesthesia's looking at a one point four percent change d- uh, decrease, and so is qualifying APM for anesthesia as well.

Remember, these proposed changes are not final, and you have a responsibility to really take a look at, you know, what they put out there and say, "Wait a minute, this doesn't really work for us." And you can, uh, comment, um, at the cms.org website, and it really...

Or I'm sorry, cms.gov website, and it'll give you some insight, and they do listen to everybody.

They don't always do what you want, but they do have to take into account everything that is, uh, said during the comment period.

Now, there's another thing on facility-based specialists, and this might apply to any listeners who, uh, your physicians are a hospital group, either employed by the hospital or an independent clinician, uh, that works at the hospital, but basically you're the, you're actually in the hospital.

And those are basically ER, um, groups and some hospitalist medicine clin-clinicians that fifty percent of hospitalists actually are independent providers, and seventy-five percent of emergency medicine clinicians are also independent providers.

And people think they actually are employees of the hospital, which they're not.

Well, when you look at indirect practice expense allocation and how they get paid, you're looking-- the proposed fee schedule actually takes money away from physicians who work in the hospital because they're not dealing with the practice expense portion of the RVU that's considered part of the facility-based, uh, expense.


And what they did is they put in an EO twelve eighty, uh, six six, EO two one two eight six six.

And just take a look, you can Google it, and they wanna have some kind of modifier that shows when there is a provider that, yes, works in a facility full-time, but they are an independent physician, uh, which means that, you know, they are also taking on that practice expense that, I don't know, sometimes the fee schedule doesn't really allow for if the location is reflective of being in a facility working instead of in an office space.
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