CMS Releases Calendar Year 2027 Proposed Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (OPPS)

The Centers for Medicare and Medicaid Services (CMS) released the 2027 Medicare Physician Fee Schedule proposed rule late on July 14, 2026, reducing the PFS conversion factor from $33.5675 to $33.1693 for qualifying alternative payment model (APM) participants and from $33.4009 to $32.8409 for non-qualifying APM participants. This is a projected decrease of $0.56, or 1.7%, from the current non-qualifying APM conversion factor of $33.40.

Highlights from the proposed rule relevant to audiology clinicians are below:

Medicare Payment Updates

Audiology services will be impacted by the broader MPFS payment update, including proposed CY 2027 conversion factor reductions resulting from expiration of the temporary CY 2026 payment increase.
The overall reimbursement for audiology services is projected to decrease roughly 3% compared with 2026, including changes to policies and individual service values. Individuals and groups will see different impacts depending on patient populations and services offered.
See the updated CY27 proposed payment table for specific detail about audiology codes.

Practice Expense Methodology Changes

CMS proposes continued reforms to practice expense methodology, including reducing reliance on historical specialty-specific PE/hour data.
These changes could affect valuation of audiology services over time, depending on final methodology and code-specific impacts.

Vestibular Assessment Services (New CPT^® Codes 92XX5, 92XX6, 92X10, and 92X11)

CMS is proposing RVU values for newly established vestibular testing codes following CPT and RUC review.

Rotational Vestibular Assessment (CPT Codes 92XX5 and 92XX6)

CPT^® code 92546 was deleted and replaced with two new codes for rotational vestibular assessment using sinusoidal harmonic acceleration (SHA) testing.
CMS proposes the RUC-recommended work RVU of 0.92 for CPT 92XX5 (base service).
For add-on CPT code 92XX6 (velocity step testing), CMS proposes a work RVU of 0.35, lower than the RUC recommendation of 0.48, citing concerns that the RUC value would result in an intensity level significantly higher than the base SHA testing service.
CMS proposes to accept the RUC-recommended direct practice expense (PE) inputs for both codes without refinement.

Video Head Impulse Testing (vHIT) (CPT Codes 92X10 and 92X11)

CMS proposes the RUC-recommended work RVUs of 0.53 for CPT 92X10 (lateral semicircular canal testing) and 0.84 for CPT 92X11 (lateral and vertical semicircular canal testing).
CMS proposes to accept the RUC-recommended direct PE inputs for both codes without refinement.

Merit-Based Incentive Payment System

CMS proposes to sunset traditional MIPS by 2029 and transition clinicians to MIPS Value Pathways (MVPs), reflecting a broader shift toward specialty-focused, value-based performance measurement. As part of this transition, CMS proposes three new MVPs focused on diabetes, hypertension, and hospital-based care, while continuing to align quality reporting with accountable care and alternative payment models.

Accountable Care Organizations (ACOs)

CMS proposes several changes to expand participation in Medicare ACOs by reducing administrative burden, enhancing financial incentives, and increasing flexibility for participating providers. The proposals are intended to make ACO participation more attractive, strengthen accountability for quality and total cost of care, and accelerate CMS’ transition from fee-for-service reimbursement to value-based, coordinated care

For CY 2027, CMS is proposing broad reforms to Medicare physician payment and value-based care designed to expand accountable care, modernize physician payment, reduce administrative burden, and advance a more preventive, coordinated approach to care delivery. Key proposals are highlighted below. Collectively, these reforms aim to improve care quality, enhance patient outcomes, and support the long-term sustainability of the Medicare program.

Below is an overview of additional provisions:

Health IT / Interoperability: CMS is seeking input on reducing duplicate testing and improving clinical data sharing through enhanced interoperability. While focused on laboratory testing and imaging, the broader effort may have implications for audiology as electronic exchange of diagnostic data and care coordination evolve. CMS is also seeking feedback on payment considerations for integrating technology into primary care. No immediate audiology payment changes are proposed.
Practice Expense (PE) Methodology: In addition to the broader PE methodology reforms described above, CMS proposes to:
- Allocate indirect PE using both work RVUs and clinical labor RVUs for all services (except those with 10- and 90-day global periods), rather than limiting this methodology primarily to services with technical, professional, and global components.
- Eliminate the Indirect Practice Cost Index (IPCI) from the PE methodology and replace it with a Practice Expense (PE) stabilization adjustment.
RFI on CPT: CMS is seeking stakeholder feedback on the role of the AMA CPT coding system and RUC in Medicare physician payment, including potential alternatives to the current coding and valuation process. CMS requests comment on the impact of CPT licensing, the development of CPT codes, and alternative approaches to coding and valuing physician services.
Redesigning Primary Care to Make America Healthy Again: CMS requests comment on modernizing primary care to emphasize prevention, address chronic disease, reflect advances in digital health and AI, and explore alternatives to traditional fee-for-service payment, including outcomes-based and prospective primary care payment models.
Remote Monitoring: CMS is proposing to require that RTM services only be furnished to established patients. CMS is also proposing to allow RPM and RTM services to be furnished only by clinical staff employed by the practice. Additionally, CMS seeks comment on creating a bundle of remote monitoring codes.
Software as a Medical Service (SaMS): CMS seeks comment on establishing a consistent Medicare payment framework for SaMS technologies across care settings. The RFI complements the CY 2027 OPPS proposal to transition certain stand-alone SaMS laboratory analyses from the Clinical Laboratory Fee Schedule to the OPPS, signaling broader agency interest in developing a long-term payment policy.
RFI on Global Surgery Packages: CMS proposes to pause the data collection required by section 523 of the Medicare Access and CHIP Reauthorization Act (MACRA) to assess how best to use the data and improve this data collection going forward. The agency requests comment on valuation approaches and data collection methods.
Ambulatory Specialty Model: CMS is offering model details ahead of the model start date on January 1, 2027. Details include revising and adding definitions, participant criteria, benchmarking and scoring methodology, and reporting requirements.
RFI on Reduction of Duplicate Testing: CMS seeks stakeholder feedback on strategies to reduce unnecessary duplicate laboratory testing and imaging by improving the sharing of test results across providers and care settings. CMS requests input on barriers to interoperability, access to prior results, and potential policy approaches to promote more coordinated care.

The Academy will continue to analyze the proposed rule and plans to submit comments by the September 14, 2026, deadline.

Additional Resources:

Calendar Year 2027 Proposed 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System

Additionally, CMS also recently released the CY 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule, outlining updates to Medicare payment policies and rates for hospital outpatient and ASC services.

Hospital Market Basket Update: CMS proposes a CY 2027 OPPS market basket increase of 2.5% for hospitals that meet quality reporting requirements, with the update reflecting a 3.2% hospital market basket increase reduced by a 0.7 percentage point productivity adjustment, as required by statute.

Included with this summary is a table of the proposed CY 2027 APC payment rates for audiology services to assist members in evaluating the reimbursement impact of the HOPPS proposed rule.