CMS issues CY 2027 Physician Fee Schedule final rule (CMS-1848-F): conversion factors fall, same-day E/M and 0-day global payment cut, new 340B Part D claims repository duty
Published November 8, 2026 · Coverage November 1–7, 2026, Pacific · High priority
On November 4, 2026, CMS released the CY 2027 Physician Fee Schedule (PFS) final rule, effective January 1, 2027; the rule was published in the Federal Register on November 9, 2026. CMS projects the qualifying alternative payment model (APM) conversion factor at $32.95 and the non-qualifying APM conversion factor at $32.63, decreases of 1.83% and 2.31% from CY 2026, after the one-year 2.50% CY 2026 statutory increase lapses. CMS finalized a payment reduction when a separately identifiable office/outpatient evaluation and management (E/M) visit is furnished on the same day as a 0-day global procedure, paying the most expensive service at 100% and the others at 80%, narrower than proposed. The proposal covered a visit furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10- or 90-day global procedure; the fact sheet says CMS made two significant modifications to it and does not restate the same-physician condition for the final policy. G2211 becomes modifier B1 (16% increase to the E/M code), and a voluntary B2 modifier (32%) is created for practitioners in a Shared Savings Program Accountable Care Organization (ACO) and Participant Providers in a Long-term Enhanced ACO Design (LEAD) Model ACO. The fact sheet says providers and suppliers that are 340B covered entities must submit claim data for covered Part D drugs billed to Medicare Part D and dispensed by the entity or its contractors (such as contract pharmacies) under a 340B discount to the Medicare Part D Claims Data 340B Repository, beginning with claims with dates of service on or after January 1, 2027, with the first quarterly submission deadline moved to September 30, 2027.
Background
Since 1992, Medicare has paid for the services of physicians and other billing professionals under the PFS, and the relative value units applied to each service become payment rates through a conversion factor. Since CY 2026 the statute has required two conversion factors, one for qualifying APM participants and one for physicians and practitioners who are not qualifying participants, and CY 2026 rates carried a one-year 2.50% conversion factor increase that does not continue into CY 2027.
Who this affects
Physicians and practitioners billed under the PFS, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), independent labs paid under the Clinical Laboratory Fee Schedule (CLFS), 340B covered entities that dispense Part D drugs (including through contract pharmacies), Shared Savings Program ACOs.
Why it matters
Inference: professional-fee revenue projections for 2027 need the lower conversion factors; charge masters and coding edits need the B1/B2 modifiers in place of G2211; same-day E/M plus 0-day global billing by the same physician or a physician in the same practice (the condition in the proposal) will pay at 80% for the lesser service; 340B programs need a process and data feed for Part D claims dispensed by the entity or its contract pharmacies starting with January 1, 2027 dates of service; remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) programs that use contracted staff have until January 1, 2029 before the employed-clinical-staff requirement applies.
Required actions
- Apply CY 2027 PFS payment and coding policies to services on or after 2027-01-01 (rule effective 2027-01-01), except where the rule sets a later start, such as the employed-clinical-staff requirement for remote monitoring services, delayed to January 1, 2029.
- Providers and suppliers that are 340B covered entities: submit the required claim data for covered Part D drugs billed to Medicare Part D and dispensed by the entity or its contractors under a 340B discount to the Medicare Part D Claims Data 340B Repository, for claims with dates of service on or after 2027-01-01; first quarterly submission for 2027-01-01 to 2027-03-31 dates of service due 2027-09-30.
Recommended action
- Model 2027 professional revenue at the final conversion factors.
- Update E/M modifier logic (B1, B2) and same-day 0-day global edits before January claims.
- Assign a 340B program owner to scope Part D repository data elements against the full rule text and contract-pharmacy data access.
- ACOs applying for 2027-01-01: decide any track change before the Phase 2 window closes 2026-11-17 at noon ET.
Implementation playbook
- Load the CY 2027 conversion factors ($32.95 for qualifying APM participants, $32.63 for others) into the 2027 professional-fee budget and contract models. Owner: Finance and Medical Group Operations. Due: 2026-12-15.
- Update charge capture and claim edits for the reduced payment when an office or outpatient E/M visit is billed on the same day as a 0-day global procedure by the same physician or a physician in the same practice (confirm the condition in the rule text), and for modifier B1 in place of G2211 (B2 only for practitioners in a Shared Savings Program ACO and Participant Providers in a LEAD Model ACO). Owner: Revenue Cycle and Coding. Due: 2026-12-31, ahead of the January 1, 2027 effective date.
- 340B covered entities: name an owner for submitting Part D claim data to the 340B Repository, confirm the data feed for dates of service from January 1, 2027, and calendar the first quarterly submission. Owner: Pharmacy 340B program and Compliance. Due: process ready 2027-01-01; first submission 2027-09-30 (the fact sheet's date).
- Shared Savings Program applicants for a January 1, 2027 start: decide on any track change. Owner: ACO leadership. Due: 2026-11-17, noon Eastern (the fact sheet's window).
- Read the published rule (91 FR 70992) for provisions the fact sheets do not cover, and check the points in this entry against the rule text. Owner: Compliance. Due: 2026-12-01.
Scope and timing
- Authority status
- Final
- Responsible owner
- Revenue Cycle (professional billing); Pharmacy/340B program for the repository duty
- Publication date
- 2026-11-09 (Federal Register, 91 FR 70992; after the window). CMS fact sheet and press release dated 2026-11-04; placed on public inspection 2026-11-04
- Effective date
- 2027-01-01
- Compliance date
- 2027-09-30: first mandatory quarterly submission to the 340B Repository, covering dates of service in the first quarter of 2027
- Implementation date
- Requirement for employed clinical staff in remote monitoring services begins with CY 2029
- Other dates
- Shared Savings Program applicants for a 2027-01-01 start may change track during the Phase 2 window, 2026-11-12 to 2026-11-17 at noon Eastern
Not established
The 2,468-page rule text was not retained (size); every fact comes from the CMS fact sheets plus the Federal Register application programming interface (API) record. Exact 340B Repository data elements, the hospital outpatient interaction with the 0-day global policy, and RHC/FQHC details were not verified in the rule text. The fact sheet's opening line reads 'On 2026' with no day.
Sources
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