Is the 2027 conversion factor final?

No. The figures are proposed in CMS-1848-P and can change in the final rule. Check CMS for the final rule before updating your fee schedule.

Does this affect commercial payers?

Often, indirectly. Many commercial contracts set rates as a percentage of the Medicare fee schedule, so a Medicare change can flow into your contracted rates. Check how your contracts reference Medicare.

What should a practice do now?

Estimate the revenue effect using your own CPT mix and the proposed values, review contracts tied to Medicare rates, and plan to load the final 2027 fee schedule in January.

2027 Medicare Fee Schedule Proposed Rule: Key Changes

On July 14, 2026, CMS released the proposed CY 2027 Medicare Physician Fee Schedule rule (CMS-1848-P). It proposes a conversion factor of $32.8409 for most clinicians, a 1.68% decrease, and $33.1693 for qualifying APM participants, a 1.19% decrease. These are proposals and may change in the final rule.

By Bill For You RCM · Published October 23, 2026. Educational information, not legal, coding or tax advice. Rules change; confirm with CMS and each payer.

The numbers

Non-qualifying APM clinicians: proposed conversion factor of $32.8409, down 1.68% from the CY 2026 figure of about $33.40.
Qualifying APM participants: proposed $33.1693, down 1.19% from about $33.27.
Why it falls: summaries of the rule attribute the decline mainly to the expiration of the one-year 2.5% increase Congress provided for 2026.
Comment period: CMS accepted public comments through September 14, 2026.

Other proposals worth knowing

Efficiency adjustment: CMS proposes to keep applying it to non-time-based services, and to apply it to some new or revised services.
Site-of-service differential: the adjustment would continue, with CMS asking for comment on effects on independent practices.
Practice expense: a multi-year update to the methodology is proposed.
Telehealth: CMS continues moving from temporary flexibilities toward a permanent framework, and proposes modifiers (that would not change payment) for certain telehealth claims involving virtual platform arrangements or incident-to services.
Telehealth originating site fee (Q3014): a proposed increase based on the Medicare Economic Index.

What practices should do now

Model your impact. Pull your top 50 CPT codes by volume and apply the proposed values to estimate the change. Impact varies by specialty and by facility vs non-facility setting.
Review payer contracts that pay a percentage of Medicare and note renewal dates.
Watch for the final rule and plan to load the 2027 fee schedule before January 1.
Prepare for new telehealth modifiers if they are finalized, and confirm your billing system can add them.
Keep denial and A/R discipline. Lower rates make every denied or aged claim matter more. See our guide to reducing claim denials.

Sources and where to verify

CMS fact sheet: CY 2027 Medicare Physician Fee Schedule proposed rule
CMS rule page: CMS-1848-P
Check CMS for the final rule and updated figures.

2027 Medicare Physician Fee Schedule Proposed Rule