The Proposed Rule issued by the Centers for Medicare and Medicaid Services (CMS) for payments under the 2027 Medicare Physician Fee Schedule (MPFS) contains a decrease from the current 2026 Conversion Factor rates. There are two different fee schedules , which are determined by a provider’s participation status in an Alternative Payment Model (APM). The Conversion Factor (CF) in the 2027 Proposed Rule is $33.1693 (down 1.2%) for Qualified Professionals (QP) or $32.8409 (down 1.7%) for non-QP’s, compared with the $33.5675 (QP) and $33.4009 (non-QP) rates currently in use.
The QP conversion factor includes a basic increase of 0.75% while the non-QP conversion factor includes an increase of 0.25%, and both include a positive budget neutrality adjustment of +0.53%. However, legislation last year provided a one-year adjustment of +2.50% for 2026, which will no longer be in effect for 2027, effectively building in a 2.5% reduction for 2027 unless changes are legislated by Congress.
The published CMS estimates indicate that the Relative Value Units (RVU) for diagnostic radiology and nuclear medicine would be positively impacted by 2% and that interventional radiology and radiation oncology would see a 3% increase due to changes in the proposed rule other than the CF. The rate of impact varies significantly depending on the site of service, as follows:
|
Subspecialty |
Imaging Center Global Fee |
Hospital Professional Fee |
Combined Impact |
|
Radiology |
2% |
1% |
2% |
|
Nuclear Medicine |
2% |
2% |
2% |
|
Interventional Radiology |
5% |
1% |
3% |
|
Radiation Oncology |
5% |
-1% |
3% |
The proposed rule for 2027 continues policies that shift reimbursement away from services provided in a facility (hospital) setting and toward office-based services. However, we do not expect that the site of service differential will apply to hospital-based diagnostic radiology services billed with Modifier -26 in keeping with the policy adopted for 2026.
Quality Payment Program
In addition to fee schedule changes, the Medicare PFS covers rules that govern the Quality Payment Program (QPP). Perhaps the biggest takeaway this year is that there are few changes to the QPP that will affect radiology practices. However, the proposed rule does solidify that traditional MIPS will no longer be available as a QPP reporting option after the 2028 performance year. Traditional MIPS will be replaced by MIPS Value Pathways (MVP) reporting beginning in 2029. This is a severe limitation for radiologists who are not able to participate in an Advanced Payment Model (APM), as there are few radiology measures available in the MVP system.
The requirement to include at least one outcome or high-priority Quality Performance measure would be replaced by the requirement to include one core measure, a new designation that would be attached to 78 Quality measures. Small practices would be exempt from this requirement.
For 2027, 3 new MIPS Value Pathways (MVP) would be added, none of which would apply to either diagnostic or interventional radiology. Virtual groups would be allowed to use MVP reporting beginning in 2029. Twenty MIPS quality measures would be removed from the available inventory, and 43 measures would be modified under the proposed rule.
The inventory of Improvement Activities would have 6 new activities added, 5 modified, and 11 removed. The new activities are in the Care Coordination and Advancing Health and Wellness subcategories, while those removed are primarily in the Care Coordination and Population Management subcategories.
The MIPS category weights would remain the same as they have been over the past few years, and the MIPS Performance Threshold will remain at 75 points through performance year 2028.
Determining Qualified Professional Status
Qualified Professionals (QP) receive a higher level of payment based on the CF differential discussed above. Currently, QP status is determined at the individual’s NPI level, meaning financial incentives flow to all practices (TINs) that a clinician bills under, including those not participating in any Advanced APM. For 2027, it is proposed that QP determinations be made at the TIN/NPI level, ensuring that financial incentives are directed only to TINs actively participating in Advanced APMs. Currently clinicians who achieve a QP designation are exempt from MIPS reporting at all practice TINs where they work, but the proposal for 2027 is that they would only be exempt from MIPS at those practices where they achieved the QP status.
Conclusion
The projected positive RVU changes, offset by the reduction in the Conversion Factor, produce varied reimbursement results for radiology based on practice setting. The impact can be estimated from the proposed rule’s fee schedule using a volume-weighted analysis for your practice. Our limited review so far shows that hospital-based practices could see a slight decrease of between 0.4 – 0.6%, while diagnostic imaging centers could see a slight increase of around 0.2%, excluding PET and other nuclear medicine exams.
CMS is accepting comments on the proposed rule until September 14, 2026, after which the Final Rule will be issued around the end of November. The Final Rule often mirrors the provisions laid out in the Proposed Rule with little change. The CF is typically modified slightly due to final calculations being applied, but there should be no significant difference.
We will provide our analysis of the Final Rule when it is issued. Subscribe to this blog for all the latest information that affects your radiology practice’s reimbursement.
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