What Does the Proposed 2027 CMS Physician Fee Schedule Mean for Primary Care?

CMS’s proposed 2027 Physician Fee Schedule sends a mixed signal to primary care. 

Primary care physicians have heard the promise many times before: primary care is the foundation of a healthier, more affordable health system.The latest proposal recognizes the importance of longitudinal care, revisits how primary care is valued, and asks how technology and prospective payment could support the work practices do between visits. But recognition is not the same as payment adequacy. The proposal also includes reductions, transitions, and new questions that could create uncertainty for independent practices. It should be viewed as an important opportunity to shape policy before it is finalized, not as a completed solution for primary care.

What the 2027 proposal would change

The proposal is not a single primary care payment reform intervention. It is a set of changes that could affect both what Medicare pays in 2027 and how CMS approaches primary care in future rulemaking. The most relevant provisions are::

• Proposed conversion-factor reductions. Medicare payment rates could decline for many services, in part because a temporary statutory increase for 2026 would expire.

• A new structure for G2211. CMS proposes replacing the separate G2211 add-on with MOD1, a percentage-based adjustment to the associated E/M service. A higher MOD2 adjustment would be available to certain Shared Savings Program and LEAD Model ACO participants. The transition could create workflow and payment risk for practices that have only recently begun billing G2211.

• A proposed reduction for certain same-date services. When a separately identifiable office or outpatient E/M service is furnished on the same date as a procedure with a 0-, 10-, or 90-day global period, CMS proposes paying the more expensive service at 100% and the other service or services at 50%.

• Requests for information on primary-care payment. CMS is asking for input on how to value primary care, account for technology-enabled care, and develop prospective payment within accountable care arrangements and potentially Original Medicare more broadly.

These changes combine immediate payment changes with broader questions about what primary care should look like in the future.

Recognition, with important limits

The proposal would make longitudinal care more visible in Medicare payment policy. It also acknowledges that stronger primary care may require payment beyond individual visits, including care management, behavioral health integration, telehealth, and communication between visits.

That direction is important. Primary care is not a series of disconnected encounters. It is an ongoing relationship that depends on context, coordination, and clinical judgment.

At the same time, the proposed ACO-related adjustment would not apply broadly to independent practices. ACO participation may be one pathway toward stronger primary-care payment, but it cannot be the only one. Practices need a payment system that supports comprehensive care whether or not they participate in an accountable care arrangement.

For that reason, CMS should continue developing a hybrid approach that combines appropriately valued fee-for-service payment with prospective per-member-per-month resources for defined primary-care services. Any future model should provide predictable support for care management, behavioral health integration, office-based E/M, telehealth, and communication between visits while preserving fee-for-service payment for complex or unpredictable services that do not fit neatly into a prospective bundle.

A concern about same-day care

The proposed same-day payment policy deserves particular scrutiny.

This policy is not a direct reduction for offering same-day appointments. The concern is what happens when a patient receives a separately identifiable E/M service and a qualifying procedure on the same date. Modifier 25 is intended to recognize significant E/M work that is separate from the procedure, yet the proposal could still reduce payment for the lower-valued service.

In primary care, one visit may appropriately include treatment for an acute problem and evaluation or management of another important condition. Reducing payment simply because both services occur on the same date could penalize comprehensive care or create pressure to schedule services separately. CMS should reconsider this proposal and consider exempting primary-care and office-based procedures.

Technology should strengthen primary care

Technology and AI can help primary-care teams create capacity, but payment policy should reward tools that strengthen the established care relationship instead of fragmenting it.

Technology-enabled services should remain connected to the patient’s longitudinal record and care plan. The primary-care clinician should remain responsible for clinical decisions, with technology serving as a complement and force multiplier rather than a separate source of disconnected recommendations.

This matters because additional data does not automatically create better care. If technology sends information to a practice without supporting coordination, interpretation, and follow-up, it can add work instead of reducing it. CMS should structure payment and reporting requirements so that technology gives care teams more capacity to deliver proactive, coordinated care rather than shifting another layer of administrative work onto already stretched practices.

The same principle should guide AI. AI can reduce documentation burden, support information management, and help teams focus more attention on patients. But adoption should be paired with appropriate transparency, privacy protections, clinician oversight, and integration into the established care relationship.

The opportunity ahead

CMS’s proposed rule is a useful signal that primary care is receiving greater attention in Medicare payment policy. It also makes clear how much work remains.

Independent practices need payment that reflects the cognitive, relational, preventive, and coordination work at the heart of primary care. They need implementation approaches that do not create new barriers or reward fragmented care. And they need a meaningful role in shaping how technology, AI, and prospective payment are incorporated into the system.

The next step should not be to declare the payment problem solved. It should be to use this proposal as a starting point for a more durable approach, one that supports continuity, strengthens independent primary care, and gives care teams the time, information, and resources to care for patients well.

Explore how Elation can help your practice deliver more proactive, coordinated care. Contact our team.