Comments Provided to CMS Regarding 2027 Payment Policies Proposed Rule
As part of its commitment to advocating for its members and the pain medicine community, ASRA Pain Medicine recently submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) regarding proposed rule CMS-1848-P, released on July 16, 2026. The rule outlines proposed Medicare Physician Fee Schedule and other Part B payment and coverage policies for calendar year 2027.
View the letter here (PDF).
Proposed Medicare Physician Conversion Factors
CMS has proposed a 2027 conversion factor of $33.1693 for qualifying Alternative Payment Model participants, a 1.19% decrease from 2026, and a conversion factor of $32.8409 for non-qualifying participants, a 1.68% decrease. These reductions are driven largely by the expiration of the temporary 2.5% payment increase enacted for 2026.
ASRA Pain Medicine is gravely concerned about further reductions in physician payment while the costs of operating a medical practice continue to rise. Medicare physician payments declined 33% between 2001 and 2025, adjusted for inflation, while CMS projects physician practice costs will increase by another 2.5% in 2027.
ASRA Pain Medicine is urging CMS to work with Congress on a long-term solution that provides meaningful annual payment updates reflecting the actual cost of delivering care.
Practice Expense Methodology Reform
CMS is continuing its multiyear effort to reform the practice expense methodology. The agency proposes expanding the use of physician work and clinical labor relative value units when allocating indirect practice expenses, eliminating the Indirect Practice Cost Index, and establishing a stabilization adjustment intended to limit significant year-to-year payment changes.
Although ASRA Pain Medicine supports a practice expense methodology that accurately reflects the resources required to provide contemporary medical services, CMS has not provided sufficient information to evaluate how these interrelated changes would affect individual CPT codes, service categories, or pain medicine practices.
ASRA Pain Medicine is urging CMS to delay implementation until stakeholders receive the code- and specialty-level information necessary to evaluate and comment meaningfully on the proposal.
Site-of-Service Payment Differential
Effective January 1, 2026, CMS began allocating only half as many indirect practice expense relative value units per work relative value unit to services provided in facilities compared with services provided in non-facility settings. For pain management specialties, the estimated impact was an 8% reduction in facility practice expense relative value units and a 7% increase in non-facility practice expense relative value units.
ASRA Pain Medicine agrees that site-of-service payment differences should be addressed but continues to oppose this methodology. Both independent and employed physicians incur substantial indirect costs, including expenses associated with staffing, billing, coding, scheduling, prior authorization, and maintaining office operations. These costs vary considerably and cannot be accurately represented through a uniform 50% reduction.
ASRA Pain Medicine also opposes using a new modifier to identify employed physicians and determine facility practice expense payments. Employment arrangements vary widely and do not reliably indicate the indirect costs incurred by an individual physician or practice.
The Society is urging CMS to repeal the 50% adjustment for 2027 until a transparent, data-driven policy can be developed.
Same-Day Evaluation and Management Services and Global Procedures
CMS has proposed reducing payment by 50% when a separately identifiable evaluation and management service is provided by the same physician—or another physician in the same group—on the same day as a procedure with a 0-, 10-, or 90-day global period. CMS is also considering applying the policy to inpatient evaluation and management services.
ASRA Pain Medicine strongly opposes a uniform payment reduction. Services reported with modifier 25 must be significant and separately identifiable from the work already included in the procedure’s global payment. CMS has not provided sufficient evidence demonstrating that a 50% overlap exists.
The proposed policy could also create unnecessary burdens for patients, particularly those in rural or underserved communities, by encouraging physicians to schedule an evaluation and a procedure on different days.
ASRA Pain Medicine is urging CMS to address specific instances of potentially duplicative work through the established misvalued-code and Relative Value Scale Update Committee review processes rather than imposing an across-the-board reduction.
Evaluation and Management Visit Complexity Add-On Code G2211
CMS is considering replacing the evaluation and management visit complexity add-on code G2211 with two payment modifiers, MOD1 and MOD2. These modifiers would increase payment for eligible evaluation and management services by 16% and 32%, respectively.
ASRA Pain Medicine opposes eliminating G2211. Pain medicine practices are still learning how to appropriately report the code for the longitudinal management of patients with complex chronic pain conditions. Replacing it with a new reporting structure would require additional education, create confusion, and increase administrative burdens.
ASRA Pain Medicine is also concerned that payment for the time, clinical judgment, intensity, and care coordination required to manage a complex chronic condition could vary based on whether a physician participates in an accountable care organization.
The Society is urging CMS to retain G2211 rather than replace it with MOD1 and MOD2.
Telehealth Flexibilities and Modifiers
ASRA Pain Medicine supports allowing a teaching physician to provide virtual supervision when either the teaching physician or the resident is physically present with the patient. This change would eliminate the current requirement for a three-way telehealth visit while maintaining appropriate supervision and patient-safety protections.
CMS has also proposed two informational modifiers, BB and BC, to distinguish telehealth services provided through third-party virtual platforms from those furnished “incident to” a physician’s professional services.
Although these modifiers would not affect payment, ASRA Pain Medicine is concerned about the additional administrative burden and potential liability associated with incorrect reporting. The Society is urging CMS to provide clear operational guidance well before the modifiers take effect on January 1, 2027.
Transition From Traditional MIPS to MIPS Value Pathways
CMS proposes ending traditional Merit-based Incentive Payment System reporting after the 2028 performance year. Beginning with the 2029 performance year, MIPS Value Pathways would become the only MIPS reporting option for eligible clinicians and groups not participating in a MIPS Alternative Payment Model.
ASRA Pain Medicine supports quality reporting systems that use meaningful clinical measures, apply appropriate financial incentives, and minimize administrative burdens. However, the proposed timeline would give pain medicine practices only two performance years to identify and transition to an appropriate pathway. Multispecialty practices could face additional challenges because of requirements to create and manage separate reporting subgroups.
ASRA Pain Medicine is urging CMS to establish a transition timeline that gives practices sufficient notice and time to develop compliant reporting workflows.
Ambulatory Specialty Model for Low Back Pain
The mandatory Ambulatory Specialty Model for low back pain is scheduled to operate from January 1, 2027, through December 31, 2031, in selected geographic areas. Participating clinicians could face payment adjustments ranging from a 9% reduction to a 9% increase based on performance.
Although CMS has proposed several clarifications to the model, ASRA Pain Medicine continues to have fundamental concerns about its design. These include mandatory participation, undefined performance thresholds, immediate downside financial risk, and an 85% redistribution percentage that could cause most participating physicians to receive payment reductions regardless of their performance.
CMS is also considering adding the MRI Lumbar Spine for Low Back Pain quality measure in 2027. ASRA Pain Medicine is concerned that its multiple-participant attribution methodology could hold clinicians accountable for imaging decisions they did not order or meaningfully influence. The Society supports attributing an imaging event to the clinician primarily responsible for managing the patient’s low back pain.
ASRA Pain Medicine supports replacing the Functional Status Change for Patients with Low Back Impairment measure with the Functional Outcome Assessment measure, which may better align with existing clinical workflows.
The Society is urging CMS to delay implementation of the Ambulatory Specialty Model for one year. If the model proceeds as scheduled, ASRA Pain Medicine recommends a transition period with reduced financial accountability. The MRI measure should also be delayed until complete specifications and attribution methodologies are available and participants have adequate time to evaluate their implications.