Academy Submits Comments on MPFS Proposed Rule CY 2027

On behalf of the membership, the American Academy of Audiology has submitted comments on the Centers for Medicare and Medicaid Services’ (CMS) Calendar Year (CY) 2027 Medicare Physician Fee Schedule (MPFS) Proposed Rule. CMS announced the proposed changes to the physician fee schedule in July and requested comments by September 14, 2026. CMS will review the 44,290 public comments received before issuing the final rule by November to go into effect on January 1, 2027.

In the comment letter, the Academy expresses deep concern with the cumulative impact on audiologists of the proposed changes. Specifically, the Academy addressed the impact of the conversion factor reduction, the proposed practice expense (PE) methodology overhaul, the continued efficiency adjustment, and CMS’s downward revision of a key new vestibular testing code. These reductions, taken together, amount to an estimated three percent cut in Medicare reimbursement for audiology services in CY 2027. The Academy urges CMS to make adjustments in the rule to mitigate the impact on audiologists, highlighting that the practice expense (PE) methodology employed by CMS disadvantages audiology’s largely non-clinical-labor diagnostic services.

The proposed rule also included several requests for information (RFI) on areas that CMS is seeking public input. The Academy responded to several: Duplicate Laboratory Testing, Imaging, and Result Sharing and Interoperability; Redesigning Primary Care to Make America Healthy Again; Current Procedural Terminology (CPT) and the RUC; and Software as a Medical Service (SaMS) Quality Payment Program.  Additionally, the Academy urged consideration of limitations for audiology in proposed changes in the Merit-based Incentive Payment System (MIPS), MIPS Promoting Interoperability Category, and the transition from traditional MIPS to MIPS Value Pathways (MVPs).

The Academy will monitor the final rule and apprise members of the final changes for CY27. 

The full comment letter is available here.