Jeanie Heck
Jeanie Heck, BBA, CCS, CPC, CRC Education Consultant, e4health

Happy Monday!

This edition of Start Smart comes in the form of another important announcement from the proposed CMS CY 2027 Physician Fee Schedule that I want to bring to your attention. This proposed change has to do with reducing payment for an E/M service when performed during the global period. Please take a moment to review the information below and have a great week!

▸ CMS CY 2027 Proposed Rule: CMS has proposed reducing payment when a separately identifiable E/M visit is provided by the same physician or same group practice on the same day as a procedure with a 0-, 10-, or 90-day global period
▸ Payment Methodology Under Proposal: The highest-valued service (either the E/M visit or the surgical procedure) would be paid at 100% of the allowable rate, while all other same-day surgical procedures or E/M visits would be paid at 50%
▸ Rationale: CMS states this change is intended to eliminate duplicate payment for practice expense components that are already bundled into the global surgical package
▸ Scope Expansion: This proposal extends the reduction to include 90-day global procedures, whereas some commercial payers currently apply the 50% reduction only to 0- and 10-day global procedures
▸ Commercial Payer Precedents: Several BCBS plans (Texas, California, North Carolina, New Jersey) have already implemented similar 50% reductions for modifier 25 E/M services billed with minor procedures (0- or 10-day global) effective between April 2024 and October 2024
▸ Effective Date for CMS Rule: The CY 2027 Physician Fee Schedule final rule is expected to be published in November 2026, with an effective date of January 1, 2027, pending finalization after the public comment period (which closes September 14, 2026)
I will provide a follow-up update once the final rule is published and the effective date is confirmed. As always, never hesitate to reach out with any coding questions!
Click Here To Download (PDF)

Get Start Smart in your inbox

Start Smart delivers practical, guideline-based coding tip sheets on high-impact topics every two weeks. Subscribe to get each new edition as it publishes.

Subscribe to Start Smart