CY2027 MPFS: Radiology Pay Cut Framework

CMS just cut radiology pay again. Nobody is surprised. That is the problem. 📉

When a payment cut lands and the collective response is a shrug, it means the erosion has become the baseline.

On July 14, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule. According to MD Revenue Group, if finalized, these policies take effect January 1, 2027. The 60-day public comment window closes September 14, 2026.

This is not a small administrative tweak. It is another compounding hit on a system the American Medical Association has already documented fell 29% in inflation-adjusted terms between 2001 and 2026.

Here is what is actually in this rule.

🔢 THE CY 2027 MPFS RADIOLOGY REIMBURSEMENT BREAKDOWN

Save this. Bring it to your next budget or contract conversation.

1. Conversion Factor Cuts (Two Tiers)
– Non-Qualifying APM participants: $32.8409, down 1.68% from the 2026 rate of $33.4009
– Qualifying APM participants: $33.1693, down 1.19% from the 2026 rate of $33.5675
– Root cause: the temporary 2.5% physician payment increase Congress enacted for CY 2026 is expiring

2. Modifier 25 Same-Day Slash (The One That Hurts Interventional)
– CMS proposes cutting the lower-valued service by 50% when a separately identifiable E/M visit is billed on the same day as a procedure with a 0-, 10-, or 90-day global period
– The highest-valued service stays at 100% of the fee schedule rate
– This directly hits interventional radiology workflows where a same-day consult and procedure are both clinically justified

3. G2211 Deletion
– The standalone G2211 complexity add-on code is scheduled for deletion
– Replaced by a 16% modifier bump on the E/M base code
– ACO-enrolled practices get a 32% bump instead

4. New Imaging Code
– A new Category I CPT code, 976XX, establishes national Medicare valuation for real-time fluorescence wound imaging services

The numbers that matter most to radiology operations:

Before: Non-APM conversion factor $33.4009
After (proposed): $32.8409
Change: minus 1.68%

Before: QPM conversion factor $33.5675
After (proposed): $33.1693
Change: minus 1.19%

Those percentages sound small. Multiply them across thousands of reads per month and the revenue erosion becomes a staffing and capital conversation fast.

💡 What this means for imaging operators and radiology groups

The conversion factor cut is the headline. But the Modifier 25 proposal is the sleeper hit.

Interventional radiology groups that routinely bill a same-day E/M alongside a procedure need to model what a 50% reduction on the lower-valued service does to their monthly revenue. That is not a billing department problem. That is a practice economics problem.

For group leaders running teleradiology overflow or managing hospital contracts, the conversion factor drop compounds. Every RVU-based contract you have is now worth slightly less. The math is quiet until it is not.

The comment window closes September 14, 2026. That is six weeks away. The ACR has already released impact tables comparing proposed 2027 rates against current 2026 rates for individual CPT codes. Use them.

I keep hearing people say Medicare reimbursement is not their main concern because their payer mix skews commercial. Fair. But commercial contracts anchor to Medicare rates. When the floor drops, the ceiling follows eventually.

We are 25 years into a documented 29% inflation-adjusted pay cut for physicians under Medicare, according to the AMA. The comment window is not just a formality. It is one of the few levers that actually moves policy before finalization.

If this framework helps you prep for a budget or contract conversation, save it and come back when it counts.

👉 Follow Jonathan Govette, CEO of Oatmeal Health, for daily healthcare insights on LinkedIn. Deeper dives in The Oatmeal Bite on Substack: https://news.oatmealhealth.com