The Centers for Medicare & Medicaid Services (CMS) has released its proposed 2027 Physician Fee Schedule (PFS), outlining changes that would reduce Medicare physician payment rates and affect reimbursement policies for evaluation and management (E/M) services, practice expenses, and global surgery.
One proposal with significant implications for retina practices would reduce payment for separately identifiable office or outpatient evaluation and management (E/M) visits performed on the same day as a procedure with a 0-, 10-, or 90-day global period. Because intravitreal injections (CPT 67028) have a 0-day global period, the proposal could affect reimbursement for office visits performed on the same day as an injection. Under the proposal, the higher-valued service would be paid at 100%, while additional same-day E/M services or procedures would be reimbursed at 50%. CMS said the change is intended to address what it considers duplicative payment under the current methodology.
In Montreal, where the American Society of Retina Specialists (ASRS) is currently holding its annual meeting, ASRS Chief Executive Officer Jill Blim called the proposal “a major reduction in reimbursement.”
Blim also expressed concern about CMS’s decision to issue a request for information on the use of modifier 25 with intravitreal injections. She said ASRS, the American Medical Association (AMA), and the American Academy of Ophthalmology (AAO) have been requesting a meeting with CMS to discuss appropriate use of the modifier. “Instead of meeting with us to collaborate on developing background materials for our members that would educate them on appropriate use, they’ve decided to issue a request for public comment,” she said. “This is unprecedented and we are looking at our best way to respond.” She added that the society intends to use the comment period to explain when modifier 25 is clinically appropriate and to encourage member participation.
"We're disappointed that CMS didn't take the opportunity to fix two things—efficiency adjustment and new indirect PE methodology—that went into effect last year that really hurt surgeons across the board, including retina specialists," Blim said. "There's just a continued downward trend in reimbursement, particularly for any surgical specialty."
Under the CMS proposal, qualifying alternative payment model (APM) participants would receive a conversion factor of $33.17, a 1.19% decrease from 2026, while nonqualifying clinicians would receive $32.84, a 1.68% decrease. CMS attributed much of the decline to the expiration of a temporary 2.5% payment increase enacted for 2026.
CMS also proposed replacing HCPCS code G2211 with a modifier that would increase payment for qualifying E/M visits by 16%, with an additional modifier available for eligible clinicians participating in certain accountable care organizations. Other proposals include new restrictions on remote physiologic and remote therapy monitoring services; a multiyear transition to a revised practice expense methodology that would replace longstanding AMA survey data with a new cost-based approach; and a request for comments on improving global surgery payment accuracy.
“Medicare physician payment is broken, and patients are paying the price,” said AMA President Willie Underwood III, MD, MSc, MPH, in a statement. “With a 33% inflation-adjusted cut to Medicare physician payment since 2001, too many physician practices are struggling to keep their doors open and care for Medicare patients.”
The American Academy of Ophthalmology (AAO) has also criticized the proposal, stating on social media, "This is difficult news, particularly at a time when physicians are already being asked to do more for patients with less." The Academy said its advocacy team is reviewing the proposed rule and has published an analysis for members.
The proposed rule is scheduled to take effect January 1, 2027, following the public comment period and publication of a final rule. RP