AAPA Urges CMS to Protect Patient Access in 2027 Medicare Payment Rule

Proposed payment reductions could increase patient burdens and limit access to timely care

September 17, 2026

AAPA has filed comments to the 2027 Physician Fee Schedule (PFS) proposed rule, urging the Centers for Medicare and Medicaid Services (CMS) to advance policies that expand access to care, strengthen Medicare payment systems, preserve telehealth flexibilities, and remove barriers to PA practice.

Comment letters to the PFS and other proposed rules are crucial to shaping healthcare policy. Using the regulatory comment process, AAPA has positively influenced policy and reimbursement for PAs and the patients they serve. AAPA has successfully advocated to authorize PAs to supervise diagnostic tests, provide essential services in psychiatric facilities, and order medications for hospice beneficiaries.

“These authorizations are critical to ensure Americans have access to medical care and demonstrate that AAPA’s advocacy efforts are making a real difference,” Sondra DePalma, DHSc, PA-C, DFAAPA, Vice President of Reimbursement and Professional Practice said.

Proposed Cut for Same-Day Services
In our comments, AAPA voiced opposition to a CMS proposal that would reduce payment when a significant, separately identifiable office visit occurs on the same day as a surgical procedure.

Under current policy, providers may receive full payment for both services when the office visit is distinct from the procedure and separately billable.

The 2027 PFS proposed rule proposes that, starting in 2027, when a separate outpatient E/M office visit is performed on the same day as a surgical procedure by the same practitioner (or a practitioner in the same group practice), CMS will pay for the most expensive service at 100% and reduce all other services by 50%. The agency argues that providing services in a single encounter shares administrative, clinical, and temporal resources, potentially leading to duplicate compensation.

However, AAPA warned that the proposal could create unintended consequences for patients by discouraging the delivery of multiple medically necessary services during the same visit. AAPA argued that the policy may incentivize providers to schedule services on separate days to avoid payment reductions, creating additional travel, time, cost, and access burdens for patients and potentially delaying care.

AAPA recommended that CMS withdraw the proposal. If CMS chooses to proceed with a similar policy in the future, AAPA recommended that the agency base any reduction on empirical evidence rather than an assumed 50% duplication of compensation.

Medicare Conversion Factor Reductions
CMS also proposed reducing Medicare payment rates in 2027 when a temporary Congressional payment increase expires at the end of 2026. The conversion factor is the dollar amount Medicare applies to the Relative Value Units (RVUs) assigned to healthcare services. Statute dictates an annual percentage increase in the conversion factor, but this has not kept up with inflation and practice expenses. To offset this, Congress has passed temporary patches that briefly increase payment but then produce apparent cuts when they expire. The current legislative fix expires December 31, 2026. Therefore, CMS has proposed a 40-cent reduction for practitioners in qualifying Advanced Alternative Payment Models and a 56-cent reduction for all other providers.

AAPA argued that the proposed 2027 conversion factor reductions underscore a fundamental problem with Medicare payment policy: repeated short-term congressional payment fixes are masking a reimbursement system that does not keep pace with inflation and the rising costs of providing care.

While CMS is required to implement the proposed reductions once the current 2.5% payment increase expires at the end of 2026, AAPA expressed concern that continued payment cuts could force practice changes that ultimately reduce patient access to care.

In our letter, AAPA urged CMS to work with Congress and stakeholder groups to secure both immediate relief from the 2027 cuts and a long-term, sustainable reform of the Medicare payment system. Specifically, AAPA supports exploring changes to budget neutrality requirements and implementing automatic annual inflationary updates tied to practice costs, noting that temporary payment patches are not a viable long-term solution and that healthcare professionals deserve a stable reimbursement system that adequately reflects the cost of delivering care.

CPT/RUC Reform and Medicare Payment Valuation
In the 2027 PFS proposed rule, CMS sought stakeholder input on alternative approaches to the CPT coding and valuation process. The CPT Editorial Panel establishes code descriptors and reporting guidelines, and the AMA/Specialty Society Relative Value Scale Update Committee (RUC) evaluates the resources required to furnish the service, largely through specialty society surveys of practitioners.

The RUC then recommends physician work, practice expense, and malpractice RVUs to CMS, which uses those recommendations, along with its own analysis, to establish payment rates in the Medicare Physician Fee Schedule.

AAPA staff and PA volunteers participate in the CPT/RUC process and serve as the only voice for PAs.

In our comments to the PFS, AAPA affirmed our position that the CPT/RUC process needs reform and recommends a practical approach by increasing provider representation and supplementing valuation with objective data.

Read AAPA’s comments.

About the Physician Fee Schedule (PFS)
Each year, CMS releases several rules that seek to update the policies of various prospective payment systems and fee schedules. Most prominent among these rules is the PFS, which annually makes major policy changes to the Medicare program.

The PFS proposed rule is typically released in early July of each year and posted for public viewing in the Federal Register. Interested parties can then review the proposed rule and provide comments in response to CMS in advance of its submission deadline, typically 60 days after the official publication in the Federal Register. Comments are submitted via regulations.gov. CMS reviews all comments to consider whether to finalize policies as proposed or to modify or retract proposals according to feedback received. CMS subsequently releases a final rule, identifying the relevant feedback on each topic and issues final determinations on its proposed policies. This final rule is released at least two months prior to the start of the calendar year in which many of the previously proposed policies are scheduled to take effect.

For questions, contact [email protected].

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