Late yesterday, the Centers for Medicare and Medicaid Services (CMS) issued the proposed rule for the Calendar Year (CY) 2027 Payment Policies under the Physician Fee Schedule (PFS) and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements.
The most encouraging news is that the proposed rule fixes a policy error from last year to recalibrate SNF physician payments to be the same for both long-stay residents and short-stay patients. More on that below.
AHCA/NCAL has performed a preliminary review of the proposed rule for provisions that have a direct impact on AHCA/NCAL members and the residents they serve. Below are highlights of the major proposal impacting our sector. AHCA/NCAL will be conducting a deeper review and will be submitting comments, which are due within 60 days of this notice.
PFS Payment Rates to Decrease Slightly
CMS has identified that providers able to participate in PFS incentive programs will have a 1.19% reduction in their PFS conversion factor in CY 2027, while providers such as SNF that are not able to participate in PFS incentive programs will have a 1.68% reduction in their PFS conversion factor. CMS attributes these reductions to the statutory update and budget neutrality calculations.
SNF Physician Payment Adjustment Equalizes Long and Short-Stay
In coordination with physician groups that serve SNF residents, AHCA/NCAL successfully advocated to CMS to restore adequate physician payments for services furnished to SNF patients during a Part A stay. In this proposed rule, CMS admits that it unintentionally imposed a payment cut for services furnished during a SNF Part A stay (approximately 12%) while increasing payments approximately 4% for long stay residents in the CY 2026 PFS rule. This has negatively impacted access to physician services for Medicare beneficiaries during a SNF Part A stay.
The CY 2027 proposed rule fixes this error and equalizes payments to the long-stay resident levels, which is welcome news for the sector.
Telehealth Policies
CMS reminds providers of Congressional extensions of most telehealth flexibilities policies through December 31, 2027; that audio-only telehealth authority is extended through January 1, 2028; and geographic and originating site restrictions remain waived through 2027. CMS proposes new telehealth billing modifiers required by the Consolidated Appropriations Act, 2026. CMS proposes adding several new services to the Medicare Telehealth List, including advance care planning and shared medical appointments.
Physical Therapy, Occupational Therapy, or Speech-Language Pathology Policies
CMS proposes increasing the annual therapy threshold based on the 2.5% Medicare Economic Index update. Proposed CY 2027 thresholds are $2,540 for Physical Therapy + Speech-Language Pathology (SLP) combined, and $2,540 for Occupational Therapy. CMS also confirms that the targeted medical review threshold remains $3,000 through CY 2027.
CMS proposes that several new SLP codes be designated as Always Therapy services. Additionally, CMS proposes a new SLP Healthcare Common Procedure Coding System (HCPCS) code GSLPP for the treatment of speech, language, voice, communication, and/or auditory processing disorders for pediatric patients.
Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM)
CMS proposes significant guardrails for RPM/RTM by requiring RTM to be limited to established patients, requiring a face-to-face (in-person or telehealth) initiating visit before RPM or RTM begins, and limiting billable services to those furnished by clinical staff employed by the billing practice (effectively prohibiting outsourced third-party monitoring vendors). CMS also proposes revaluing RPM/RTM payments.
Overall, CMS signals a broader shift toward simplified, integrated remote monitoring, requesting comment on replacing the current 17 RPM/RTM CPT codes with four bundled HCPCS G-codes.
Medicare Shared Savings Program
Overall, the proposals are intended to encourage greater provider participation in the Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs) through stronger financial incentives and reduced administrative burden. There are no major proposals specifically targeting SNF payment, SNF quality reporting, or post-acute care within MSSP comparable to prior years' discussions around beneficiary assignment after SNF stays. Most changes are focused on financial methodology, program administration, and quality reporting.
These changes could indirectly strengthen ACO-SNF partnerships by making ACO participation more attractive and reducing administrative complexity.
Please contact AHCA/NCAL’s Associate Vice President of Therapy Advocacy Daniel Ciolek with questions about the PFS Proposed Rule or Vice President of Reimbursement Policy & Population Health Nisha Hammel with questions about MSSP.