CMS Releases Final Medicare Physician Fee Schedule and Hospital Outpatient Payment Rates and Policies for 2027

The Centers for Medicare & Medicaid Services (CMS) has released the 2027 Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (HOPPS) final rules. In the days ahead, your ASNC advocacy team will analyze the rule and report on specifics that may impact your practice.

We are able to share the following top-line analysis of several key proposals while ASNC’s policy experts conduct additional code-specific analysis.

Hospital Outpatient Prospective Payment System

Hospital Outpatient Payment Update

CMS has finalized a 2.3% facility payment increase for hospital outpatient departments that meet quality reporting requirements. CMS finalized the proposed changes to 340B payment methodology and, because statute requires budget-neutral implementation, the increase to non-drug services will be finalized for 2027, resulting in a reimbursement increase for nuclear cardiology. Watch for details!

Reorganization of the Nuclear Medicine and Related Services Ambulatory Payment Classifications

CMS finalized assignment of CPT codes 78431 through 78433 from new technology ambulatory payment classifications (APCs) to clinical APC 5594. ASNC strongly supported this proposal and is pleased that PET/CT services have been placed in a clinical home APC. For additional analysis on 2027 rates, stay tuned to ASNC.

Payment for Diagnostic Radiopharmaceuticals

Continuing with its packaging policy for radiopharmaceuticals, CMS finalized a per-day cost threshold that triggers separate payment for diagnostic radiopharmaceuticals from the current $630 to $635. CMS lowered the threshold from the proposed $665 based on most recent data available. For radiopharmaceuticals paid separately, CMS will continue setting reimbursement using the arithmetic mean unit cost as a proxy for the average price for a diagnostic radiopharmaceutical.

Site-Neutral Payment Policy for Non-contrast Imaging

Citing an increase in the volume of imaging services paid for in the hospital outpatient department and an increase in utilization per beneficiary despite a declining Part B fee-for-service beneficiary population, CMS is using its authorities to extend its site-neutral payment policies to non-contrast imaging services when furnished at an excepted, off-campus provider-based department. Under the final rule, CMS will apply the MPFS-equivalent payment rate to Healthcare Common Procedure Coding System codes assigned to the imaging without contrast APCs. CMS said it received comments in support of extending its policy to additional imaging services, including nuclear medicine, and may take those comments into consideration in future rulemaking.

Medicare Physician Fee Schedule

Conversion Factor

Again for 2027, and per statute, CMS’s proposed conversion factor varies depending on whether a physician successfully participates in an alternative payment model (APM). For both qualified APM participants and non-APM participants, the conversion factor is reduced as a result of the expiration of the 1-year 2.5% conversion factor provided by Congress for 2026.

• The 2027 proposed conversion factor for physicians not participating in an APM is $32.63, a decrease of $0.77 (-2.31%).
• For qualified APM participants, the proposed 2027 conversion factor is $32.95, a decrease of $0.62 (-1.83%).

Medicare Physician Payment Policy

• Practice Expense: CMS finalized a multi-year overhaul of the indirect practice expense (PE) RVU methodology intended to reduce reliance on outdated specialty-specific practice expense per hour data. The changes include a revised calculation based on work and clinical labor RVUs, a 2-year phase-out of the Indirect Practice Cost Index by 2028, a new stabilization adjustment intended to limit annual PE RVU fluctuations to approximately 5%, and revisions to how payment modifiers and special payment rules factor into PE calculations. Collectively for nuclear cardiology, these changes result in a modest decrease in non-PET reimbursement.

• Efficiency Adjustment: CMS is maintaining the efficiency adjustment that took effect this year and cuts the physician work intraservice time by 2.5% for all non-time-based services. As previously finalized, the efficiency adjustment will be recalculated and reapplied every 3 years, with the next update occurring in 2029.
• Evaluation and Management (E/M) Resource Overlap Between Stand-Alone Visits and Global Periods: CMS will apply a 20% payment reduction when separately identifiable office/outpatient E/M services are reported with modifier -25 on the same day with the same practitioner as a procedure with a 0-day global period. The same pay reduction will apply to a practitioner of the same specialty in the same group practice. The highest value service will be paid at 100% and all other services will be paid at 80%. CMS had proposed to apply the policy to 0-, 10- and 90-day global periods with a 50% reduction. ASNC opposed the proposal because of the effects on cardiovascular practices.

Imaging Duplication and Interoperability

In the proposed rule, CMS issued a request for information (RFI) to gather input that could inform potential actions aimed at addressing CMS’s concerns about duplicate imaging testing, including by improving electronic interoperability. In its comments letter, ASNC cautioned CMS that any effort to curb duplicative imaging tests should be preceded with a clear and clinically appropriate distinction between repeat or follow-up testing vs. duplicative imaging tests. In the final rule, CMS acknowledges commenters who noted that often times duplicate testing may be clinically necessary, and healthcare providers should not be penalized if access to prior results is not readily available. Responses to the RFI will be used to inform future CMS rulemaking.

Ambulatory Specialty Model for Heart Failure

CMS is proceeding with its Ambulatory Specialty Model (ASM) for Heart Failure, which will begin on Jan. 1, 2027. The ASM for Heart Failure is a mandatory program aimed at holding physicians accountable for the quality and cost of care associated with the management of specific chronic conditions, including heart failure. CMS finalized changes to the model to help clarify how the model functions and which specialists are required to participate in the model.

Stay Tuned for More Analysis

For more information on the 2027 Hospital Outpatient Prospective Payment System final rule, refer to these CMS resources:

2027 Hospital Outpatient Prospective Payment System Final Rule
2027 Hospital Outpatient Prospective Payment System Final Rule Fact Sheet

2027 Medicare Physician Fee Schedule Final Rule
2027 Medicare Physician Fee Schedule Final Rule Fact Sheet

In the coming days, we will provide ASNC members with charts compiling the 2027 payment rates for all nuclear cardiology services in the MPFS and HOPPS final rules. These charts are valuable tools for practice management and budgeting.

If you want to receive the payment charts, additional analysis of the final rules, and other advocacy updates, you must be an ASNC member. Join ASNC now.

ASNC Members: Renew your membership for 2027 now to ensure you receive ASNC’s alerts on policy developments, including time-sensitive calls to action.