The 2027 Proposed Rule is Out. Here's What You Need to Know.

School may not be back in session quite yet, but for healthcare providers, it’s required reading season all the same. That’s right, the 2027 proposed rule is at hand (or rather, on a laptop), and with it comes a flurry of updates to payment and coding and rules within Medicare Part B.

You’ve got plenty on your plate already, though, which is why I’ve reviewed over 1,500 pages to pull out the relevant updates for rehab therapists.    

Both conversion factors get a cut.

Last year introduced a new wrinkle into provider pay: two conversion factors, one for providers participating in alternative payment models (APM) and one for those not participating. Unfortunately, neither has fared well in the latest update: the qualifying APM conversion factor has dropped from 33.5675 to 33.1693, while the non-qualifying APM conversion factor has decreased from 33.4009 to 32.8409.   

However, hope is not lost: the 2026 conversion factors increased from 2025 levels due to a 2.5% statutory bump, so there’s still a chance Congress will act to improve pay.   

The therapy threshold increases again.  

One number we can count on rising is the therapy threshold, and CMS didn’t disappoint, at least on this front. The proposed CY 2027 KX modifier threshold amounts are $2,540 for physical therapy and speech-language pathology services combined, and $2,540 for occupational therapy services, up from $2,480 in 2026. 

The targeted medical review threshold stays steady at $3,000 for 2027, although CMS notes that beginning in 2028, the figure will be annually updated by the percentage increase in the Medicare Economic Index (MEI).

CMS is considering significant changes to RTM. 

The addition of remote therapeutic monitoring codes noted major progress for rehab therapists, and in the intervening years CMS has tweaked the codes with every new rule. Now, they’re proposing what might be major overhauls. 

Perhaps the biggest potential change is CMS’ current consideration to bundle CPT codes 99453, 99445, 99454, 99091, 99470, 99457, 99458, 98975, 98984, 98976, 98985, 98977, 98986, 98978, 98979, 98980, and 98981 through the creation of new codes that describe the initial set up and monthly monitoring/management for RPM and RTM. 

Under this proposal, CMS would create four new HCPCS G-Codes:  

• GRPM1: RPM initial set-up and patient education.
•  GRPM2: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), per calendar month, including:
  
  • Device(s) supply with daily recording(s) or programmed alert(s) transmission.
  • 2 or more days of data transmission.
  • Treatment management services, requiring at least one real-time interactive communication with the patient/caregiver; time totaling at least 20 minutes.

• GRTM1: RTM initial set-up and patient education.
• GRTM2: Remote monitoring of therapeutic parameter(s) (eg, therapy adherence, therapy response, digital therapeutic intervention), per calendar month, including:
  
  •  Device(s) supply for data access or data transmissions.
  • 2 or more days of data transmission.
  • Treatment management services, requiring at least one real-time interactive communication with the patient or caregiver; time totaling at least 20 minutes.

Spurred by what it states are claims from the Office of the Inspector General that some providers were furnishing RTM services to people who weren’t patients, CMS is proposing that a requirement of RTM services be that they are only provided to established patients. CMS’ rationale is that “we believe that a practitioner with an established relationship with a patient would likely have had the opportunity to collect relevant patient history and conduct a physical exam, as appropriate.” 

Additionally, CMS is proposing that providers making use of RTM or RPM must “furnish a separately reportable initiating visit in association with the onset of RPM or RTM services, since these services require a level of care coordination that cannot be effective without appropriate evaluation of the patient's needs.” This visit would have to be face-to-face, either in person or via telehealth, and would purportedly allow clinicians to determine the appropriateness of RTM or RPM services. 

Notably, CMS states that “(i)f RPM or RTM is not discussed with the patient at that visit, that visit cannot count as the initiating visit for RPM or RTM. The RPM or RTM initiating visit can be separately billed.”

CMS is proposing to eliminate the furnishing of RTM services by a third-party employed by a practice: We are proposing to only allow payment for RPM or RTM services when furnished by clinical staff employed by the practice. To count the time spent by clinical staff providing aspects of RPM or RTM services, the clinical staff must be a direct employee of the practitioner or the practitioner's practice.

CMS is also seeking comment on its proposals to crosswalk some of the RTM codes — specifically, crosswalking code 98975 to the direct PE inputs associated with CPT code 99473 and codes 98976, 98977, 98978, 98984, 98985, and 98986 to the direct PE inputs from CPT code 93270. CMS is also proposing to eliminate PR inputs to codes 98979, 98980, and 98981, while maintaining the current work RVUs and current work times, and seeking comment on the change. 

SLP coding changes are in the offing—but not from CMS. 

Something that has not been proposed but rather implemented by the AMA’s CPT Editorial Panel is the deletion of CPT code 92507 (Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual), as of January 1, 2027. In its place will be ten new time-based codes: 

• 92X0X — Treatment of fluency disorder (eg, stuttering and cluttering), direct (one-on-one) patient contact; initial 30 minutes
• 92X1X — Treatment of fluency disorder (eg, stuttering and cluttering), direct (one-on-one) patient contact; each additional 15 minutes
• 92X2X — Treatment of speech sound production disorder (eg, articulation, phonological process, apraxia, dysarthria), direct (one-on-one) patient contact; initial 30 minutes
• 92X3X — Treatment of speech sound production disorder (eg, articulation, phonological process, apraxia, dysarthria), direct (one-on-one) patient contact; each additional 15 minutes
• 92X4X — Treatment of language disorder (eg, receptive, expressive, or pragmatic language), direct (one-on-one) patient contact; initial 30 minutes
• 92X5X — Treatment of language disorder (eg, receptive, expressive, or pragmatic language), direct (one-on-one) patient contact; each additional 15 minutes
• 92X6X — Treatment of voice and upper airway disorder (eg, resonance, voice quality), direct (one-on-one) patient contact; initial 30 minutes
• 92X7X — Treatment of voice and upper airway disorder (eg, resonance, voice quality), direct (one-on-one) patient contact; each additional 15 minutes
• 92X8X — Treatment of voice, upper airway dysfunction, and/or resonance disorders, direct (one-on-one) patient contact; initial 30 minutes
• 92X9X — Treatment of voice, upper airway dysfunction, and/or resonance disorders, direct (one-on-one) patient contact; each additional 15 minutes (list separately in addition to code for primary service)
• 92508 — Treatment of speech, language, voice, communication, and/or auditory processing disorder, group, 2 or more individuals 

CMS is proposing to designate these codes as always therapy services, and suggesting the RUC-recommended work RVUs of 0.92 for CPT code 92X0X, 0.44 for CPT code 92X1X, 0.90 for CPT code 92X2X, 0.44 for CPT code 92X3X, 1.00 for CPT code 92X4X, 0.48 for CPT code 92X5X, 1.00 for CPT code 92X6X, 0.50 for CPT code 92X7X, 0.98 for CPT code 92X8X, 0.48 for CPT code 92X9X, and 0.28 for CPT code 92508.

CMS also notes that advocates from the SLP community have expressed their desire to maintain code 92507 specifically as it relates to treating the pediatric population. They are proposing the creation of a new HCPCS code, GSLPP, to accurately reflect the time and resources spent in providing these services to pediatric patients. This code could be billed only once per patient per day

SLP is slated for a telehealth addition.

This year’s proposed rule didn’t hold the same intrigue for rehab therapists as in years past, where telehealth privileges remained perpetually on the bubble, but there was one notable addition. CMS is proposing to add HCPCS G-codes GSLPP (Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual; for the pediatric population up to age 18 or 21) to the Medicare Telehealth Services List. 

Health coaching might be getting CPT codes.  

In the 2026 proposed rule, CMS sought comment on the creation of coding and payment for health coaching and motivational interviewing, and the result has been the creation of three new codes: 

• 0591T (Health and well-being coaching face-to-face; individual, initial assessment, 60-90 minutes), 
• 0592T (Individual, follow-up session, at least 30 minutes), and 
• 0593T (Health and well-being coaching, group [2 or more individuals], at least 30 minutes).

Here is the proposed prefatory language for codes 0591T, 0592T, and 0593T: 

“Health and well-being coaching is a patient-centered approach wherein patients determine their goals, use self-discovery or active learning processes together with content education to work toward their goals, and self-monitor behaviors to increase accountability, all within the context of an interpersonal relationship with a coach. The health and well-being coach is qualified to perform health and well-being coaching by education, training, national examination and, when applicable, licensure/regulation, and has completed a training program in health and well-being coaching whose content meets standards established by an applicable national credentialing organization. The training includes behavioral change theory, motivational strategies, communication techniques, health education and promotion theories, which are used to assist patients to develop intrinsic motivation and obtain skills to create sustainable change for improved health and well-being.”

Unsurprisingly, CMS is seeking comments on the valuation of these services and the conditions of payment, and on whether they should consider creating HCPCS G-codes to describe these services for CY 2027 as opposed to actively pricing these Category III CPT codes.

Comment is requested on Caregiver Training Services.

In the 2025 final rule, CMS implemented coding for caregiver training under the HCPCS codes G0541, G0542, and G0543. Now, they’re seeking comment on “whether the resource costs associated with these services are  best reflected through this existing coding or whether these resources costs are reflected in the valuation of other codes paid under the PFS, such as E/M visits.”

MIPS and MVPs are undergoing their annual updates.  

Let’s hit the highlights on changes under the Quality Payment Program (QPP). For a start, CMS is clarifying that the scoring weights for the 2027 performance year/2029 payment year are 30 percent for the quality performance category, 30 percent for the cost performance category, 25 percent for the Promoting Interoperability performance category, and 15 percent for the improvement activities performance category.

Specific to rehab therapy, here’s what’s changing in MIPS and the MSC MVP.

Process Measures

• Documentation of Current Medications in the Medical Record: Updated value set/coding
• Preventive Care and Screening: Screening for Depression and Follow-Up Plan: Modified collection type, measure description and measure numerator revised, updated definition and guidance for the eCQM collection type, updated numerator definition, and updated denominator exception
• Dementia: Education and Support of Caregivers for Patients with Dementia: Revised measure description and measure numerator, updated intent and clinician applicability 
• Assessment of Cognitive Impairment or Dysfunction for Patients with Parkinson’s Disease: Updated denominator criteria
• Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented: Updated denominator criteria

Quality Measures

• Adding Functional Improvement for Patients with Neck Impairments quality measure to replace current MIPS quality measure Q478: Functional Status Change for Patients with Neck Impairments
• Adding Functional Improvement for Patients with Upper Extremity Impairments to replace current MIPS quality measure Q221: Functional Status Change for Patients with Shoulder Impairments and Q222: Functional Status Change for Patients with Elbow, Wrist or Hand Impairments
• Adding Functional Improvement for Patients with Back Impairment to replace current MIPS quality measure Q220: Functional Status Change for Patients with Low Back Impairments
• Adding Functional Improvement for Patients with Lower Extremity Impairments to replace current MIPS quality measures Q218: Functional Status Change for Patients with Hip Impairments and Q219: Functional Status Change for Patients with Lower Leg, Foot or Ankle Impairments
• Adding Functional Improvement for Patients with Knee Impairments to replace  current MIPS quality measure Q217: Functional Status Change for Patients with Knee Impairments

As far as mooted program-wide changes, CMS is proposing:

• Sunsetting traditional MIPS to transition fully to MVPs reporting option beginning with the 2029 performance year/2013 payment year 
• Transitioning existing quality measures and reporting processes to Fast Healthcare Interoperability Resources® (FHIR®)-based digital reporting options.
• Adopting three new MVPs: Diabetic Disease, Hospitalist, and Hypertension.
• Removing the current quality measure data submission requirement of one outcome measure (or, if an outcome measure is not available, one high-priority measure) for traditional MIPS and MVPs, and replacing it with a MIPS core measure data submission requirement. 
  
  • Exempting small practices from the MIPS core measure data submission requirement.
• A year of optional reporting for the previously finalized requirement that MIPS-eligible clinicians must report the Electronic Prior Authorization measure to be considered a meaningful EHR user for the CY 2027 performance period/2029 MIPS payment year

The new Ambulatory Specialty Model is already getting tweaks. 

If you cast your minds back to the 2026 proposed rule — and final rule — you might recall that CMS introduced a new care model called the Ambulatory Specialty Model (ASM), which covers both heart failure and low back pain. The model encompasses providers who, as CMS states, “commonly treat Original Medicare beneficiaries in an ambulatory setting, develop longitudinal relationships with patients, and co-manage beneficiaries with primary care providers (PCP).” 

For the low back pain portion of ASM, CMS finalized inclusion of specialists in anesthesiology, pain management, interventional pain management, neurosurgery, orthopedic surgery, or physical medicine and rehabilitation.

While the program is still ramping up, the continued emphasis suggests that rehab therapists will play an increasingly big role. For the truly committed, here is the raft of changes to the program that CMS is implementing in 2027: 

• Revising select ASM definitions and adding new ASM definitions.
• Clarifying ASM participant exceptions from specified model requirements due to taxpayer identification number (TIN) changes before or during an ASM performance year.
• Excepting certain ASM heart failure participants from specified model requirements due to a redesignated specialty type.
• Incorporating an option to terminate ASM participants under certain circumstances.
• Incorporating an option for data submission for the improvement activities ASM performance category at either the individual or group level.
• Clarifying the scoring of multiple quality measure data submissions from ASM participants in small practices.
• Adding an administrative claims-based low back pain imaging quality measure and replacing the patient-reported outcome measure for low back pain with a functional status outcome process measure.
• Adjusting benchmarking and scoring policies for quality measures.
• Adding a quality ASM performance category scoring incentive for the voluntary submission of patient-reported outcome (PRO) data to support the development of patient-reported outcome performance-based measures (PRO-PM) under ASM.
• Revising requirements of the Promoting Interoperability ASM performance category to align with proposed changes to the Merit-based Incentive Payment System (MIPS) Promoting Interoperability performance category and adding a Promoting Interoperability measure suppression policy.
• Incorporating a rural scoring adjustment for ASM participants in rural areas.
• Revising the contents of the ASM performance report to include additional information related to scoring-related proposals in this proposed rule.
• Clarifying language on the application of ASM payment adjustments when an ASM participant reassigns billing rights to a new TIN during an ASM payment year.
• Clarifying the availability of the CMS-sponsored model arrangements and patient incentives safe harbor and applicability of programmatic waivers for ASM to reflect that such flexibilities are associated with active performance under ASM and would not be available or applicable during an ASM performance year in which an ASM participant is either ineligible for, or excepted from, specified model requirements.
• Revising provisions establishing collaborative care arrangement (CCA) requirements to improve clarity and update the permissible parties, remuneration conditions, documentation requirements, and compliance terms.
• Clarifying and reorganizing select regulatory text to improve readability and flow. 

Sound off in the comments. 

If you’re still reading, congrats! You’ve made it to what is, year after year, unquestionably our longest blog post. I appreciate your patronage, and applaud your bravery. 

Here is the part where I encourage any of you who are displeased with what CMS is proposing to head over to the Federal Register and lodge your complaints. It’ll take a village, or maybe more, to effect change.