In July 2026, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2027 Proposed Physician Fee Schedule (PFS) Rule, outlining updates to Medicare Part B payment systems. The proposal includes modifications across physician services, standardization of non-sheet skin substitute reimbursement and the reintroduction of modifier-25 payment reductions - which may directly affect wound debridement encounters - to the extension of telehealth flexibilities through 2027, addition of reimbursement code for real-time fluorescence wound imaging  and the strategic evolution of Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs). 

These policies are proposed, not final. Practices should not change billing or clinical workflows solely in response to the proposed rule.

CMS may revise or decline to finalize individual provisions after reviewing public comments.

Comment Period

• Comments are open until September 14, 2026, and can be submitted via Regulations.gov referencing CMS‑1848‑P. 

At a Glance: Key Takeaways for Wound Care Practices

Wound-care clinicians can provide feedback to CMS and plan for the following operational considerations under the proposed CY 2027 rules:

• Same-Day E/M and Procedure Payment: CMS proposes reducing payment when a separately identifiable office/outpatient evaluation and management (O/O E/M) service is reported with modifier 25 by the same physician - or a physician in the same group - on the same day as a procedure with a 0-, 10-, or 90-day global period. Practices should estimate the potential financial effect on common same-day E/M and procedure combinations, including applicable debridement encounters, and reinforce documentation supporting when an E/M service is significant and separately identifiable. Coding should continue to reflect the services actually furnished.
• Skin Substitute Standardization: CMS proposes replacing contractor pricing for nonsheet-form skin substitutes with national pricing aligned with rates for sheet-form products. For nonsheet products, the reported square centimeters would represent the wound surface area treated rather than the product’s physical dimensions.
• Real-Time Fluorescence Wound Imaging: CMS proposes establishing payment and valuation for placeholder CPT code 976XX, which describes real-time fluorescence imaging to identify bacterial presence, location, and load and measure wound size.
• Remote Monitoring and Telehealth: Broad Medicare telehealth flexibilities have been extended through December 31, 2027. Separately, CMS proposes requiring remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) to begin with a reportable in-person or telehealth visit and limiting RTM to established patients. Practices using remote monitoring should evaluate how the proposed initiating-visit, established-patient, and supervision requirements could affect their workflows if finalized.
• MIPS and MVP planning: Beginning with the CY 2029 performance period/2031 MIPS payment year, CMS proposes requiring most MIPS-eligible clinicians to report through a MIPS Value Pathway, except those reporting through the APM Performance Pathway. Clinicians can use the proposed transition period to identify applicable MVPs and assess their measures, reporting systems, and workflows.
• Value-based Participation and ACO-related Payment Proposals: Clinicians furnishing services through ACO would be eligible to receive a proposed 32% E/M complexity increase (via G2211 modifier expansion) and access to performance-based incentives that mitigate the volatility of traditional Fee-for-Service billing.
• Proposed E/M Payment Modifiers, Including Enhanced accountable care organization (ACO) Payment: CMS proposes replacing HCPCS G2211 with MOD1, valued at 16% of the associated E/M service’s total relative value units (RVUs). Eligible Shared Savings Program and LEAD ACO clinicians could voluntarily use MOD2, valued at 32%, when the visit meets the proposed increased-complexity criteria. MOD2 would not apply automatically to every clinician treating an ACO-associated beneficiary.

As CMS continues to refine its valuation methodologies and prioritize longitudinal, value-based care, understanding these proposals is essential for navigating the evolving reimbursement climate and ensuring operational stability in your wound care practice.

2027 CMS PFS Proposals Relevant to Wound Care Practices

CY 2027 PFS Rate Setting and Conversion Factor

In accordance with statutory mandates, CMS will maintain two distinct conversion factors starting in CY 2026: 

• Qualifying alternative payment model (APM) Participants (QPs): 
• Clinicians achieve QP status by meeting specific participation thresholds within APM, which prioritize clinical accountability for patient outcomes and resource efficiency.
• The proposed CY 2027 qualifying APM conversion factor is set at $33.17, reflecting a projected decrease of $0.40 (-1.19%) from the current rate of $33.57.
• Physicians and practitioners who are not QPs: 
• For providers not meeting QP requirements, the proposed CY 2027 non-qualifying APM conversion factor is $32.84, representing a 1.68% reduction ($0.56) from the existing $33.40 baseline.

Evaluation and Management (E/M) Visit Overlap with Global Periods

• E/M visit rules: Although not finalized in previous cycles, CMS is reintroducing a proposal for CY 2027 to reduce reimbursement for office or outpatient (O/O E/M) visits when billed using modifier –25 on the same day as a global procedure (0-, 10-, or 90-day). This shift could impact wound care encounters that involve debridement or other procedural interventions.
• Modifier –25 denotes a significant, separately identifiable office/outpatient evaluation and management (O/O E/M) visit by the same physician or other qualified health care professional on the same day as a procedure or other service.
• Under the proposal, the highest-valued service - whether the E/M or the surgical procedure - would be reimbursed at 100%, while any additional surgical procedure(s) or E/M visits on that day would be paid at a 50% rate.
• CMS projections indicate that:
• Otolaryngology, dermatology, and podiatry would face the largest negative impacts, with hand surgery and physician assistants affected to a lesser extent.
• The specialties projected to receive the most significant increases are clinical psychologists and clinical social workers.
• Conversely, most other specialties, including vascular surgery and therapy services and nurse practitioners would receive minor increases via RVU redistribution.
• Table D-B5 of the CY 2027 PFS proposed rule shows the projected impact on PFS payment for physicians’ services based on the proposed policies included in this rule. 

Proposed Revisions to E/M Visit Complexity Add-On (HCPCS G2211)

For the CY 2027 PFS, CMS is proposing two modifications to HCPCS code G2211, the visit complexity add-on established in 2025, to further refine payment for longitudinal care. 

• Transition to modifier-based billing: CMS proposes converting HCPCS code G2211 into a specific two-digit modifier. This shift would replace the current placeholder (MOD1) and allow practitioners to append the complexity indicator directly to the primary E/M service code.
• Under this structure, the modifier would trigger a 16% payment increase for the base E/M visit, ensuring a uniform percentage adjustment across all E/M code levels rather than a fixed-dollar add-on. 
• Enhanced reimbursement for ACO participants: A secondary modifier (replacing placeholder MOD2) is proposed for clinicians participating in a Medicare Shared Savings Program ACO or the Long-term Enhanced ACO Design (LEAD) Model.
• This specialized modifier would provide a 32% increase for associated E/M encounters. This higher valuation recognizes the substantial resource demands of longitudinal management, including care coordination, quality reporting, and total cost of care accountability required within these integrated models.

Proposed Revisions to Skin Substitute Payments

• For Calendar Year (CY) 2027, CMS proposes replacing contractor pricing for nonsheet-form skin substitutes with national pricing aligned with rates for sheet-form products. For nonsheet products, the reported square centimeters would represent the wound surface area treated rather than the product’s physical dimensions.

Advancing Wound Care with Real-Time Fluorescence Wound Imaging

The CPT Editorial Panel established code 976XX  in September 2025 to formalize reporting for fluorescence imaging within professional practice. For CY 2027, CMS is proposing reimbursement for this service.

• Clinical purpose: Real-time fluorescence wound imaging provides clinicians with immediate visualization of bacterial presence and wound architecture. The procedure, defined under CPT code 976XX, enables real-time imaging under clinical darkness to identify the presence, location, and bacterial load, as well as measure wound size. This approach supports earlier recognition of infection risk and facilitates targeted intervention.
• Proposed Valuation: For CY 2027, CMS has proposed:
• Work RVU of 0.80 and a total physician time allocation of 26 minutes for this service, including pre-evaluation, intraservice, and post-service work. 
• Direct practice expense crosswalks were adapted from the previous ultrasound wound assessment code (97610) with supplementary labor for surgical instrument cleaning and preparation, totaling 42 minutes of clinical labor.
• The imaging process employs specialized equipment such as the MolecuLight DX System (ER131) and the associated DX Eco Dark Drape (SB061), which ensures light-controlled conditions for accurate fluorescence detection. These tools were approved for inclusion in the CMS direct practice expense database, with equipment valuation reflecting a 5-year useful life.
• CMS is seeking feedback: Clinically, this technology is distinct from wound debridement codes because 976XX pertains exclusively to imaging rather than physical tissue removal or wound cleansing. However, CMS acknowledges potential concurrent billing with debridement as adoption broadens and has solicited clinical feedback on whether supply utilization may overlap between imaging and debridement procedures.

Low-Frequency, Non-Contact, Non-Thermal Ultrasound Wound Therapy

Low-frequency, non-contact, non-thermal ultrasound wound therapy (CPT 97610) is undergoing revaluation as a potentially misvalued code. These changes aim to align reimbursement with clinical realities and maintain parity between non-facility and outpatient payment structures CMS proposals include:  

• Potential update in the supply cost: CMS proposes to update payment for the SA119 ultrasound therapy kit—often used with MIST therapy systems—from $320.18 to $100 based on submitted pricing information and proposes reducing assumed intraservice time from 15 to 6 minutes.
• Potential update in physician intraservice time: CMS proposes to reduce physician intraservice time for this code, as manufacturer data suggest a typical average of 6 minutes versus the currently assumed 15 minutes.

Updates on Autologous platelet-rich plasma (PRP)

Autologous platelet-rich plasma - or another autologous blood-derived product - used to treat certain diabetic chronic wounds or ulcers with an FDA-cleared device is reported under HCPCS G0465. The code includes, as applicable, administration, dressings, phlebotomy, centrifugation or mixing, and other preparatory procedures per treatment.

• CMS received a request to increase the work RVUs from 1.78 to 5.50 based on a third-party survey of physicians and qualified health professionals, but noted concerns about the survey’s representativeness because it included only 34 respondents.
• CMS also continued to consider the multiple-procedure payment reduction applicable when multiple units are billed to the same beneficiary on the same day because of overlapping resource costs, and therefore did not propose the requested work-RVU increase.
• CMS is seeking comment on whether G0465 is commonly billed with wound debridement codes, including CPT 11042 and 97597, and whether proposed direct practice-expense inputs duplicate resources already included in those services. 

Updates on Hyperbaric Oxygen Therapy

Proposals related to hyperbaric oxygen therapy include:

• Maintenance of  HCPCS code G0277: CMS proposes retaining separate reporting of G0277 rather than adopting the RUC recommendation to delete it and consolidate treatment delivery into CPT 99183. HCPCS code G0277 reports hyperbaric oxygen under pressure in a full-body chamber per 30-minute interval. The code was created to describe treatment-delivery practice expense inputs associated with CPT 99183 and to maintain consistency between the OPPS and Physician Fee Schedule coding systems.
• Although the Relative Value Scale Update Committee (RUC) recommended deleting G0277 and revising CPT 99183 to describe treatment delivery, attendance, and supervision in a single time-based structure, CMS proposes to maintain G0277 because of its broad operational use. 

Proposed Revisions to Skin Cell Suspension Autograft (SCSA)

For CY 2027, CMS is proposing the following changes related to skin cell suspension autograft (SCSA):

• The CPT Editorial Panel created four new SCSA codes in September 2025: 15X19 and 15X20 for the trunk, arms, and/or legs, and 15X21 and 15X22 for the face, scalp, eyelids, mouth, neck, ears, orbits, genitalia, hands, feet, and/or multiple digits. The codes distinguish the first 100 cm² - or 1% of body area in infants and children - from each additional 100 cm² or 1% increment. The prior eight SCSA codes, 15011–15018, were deleted, and the SCSA guidelines were revised.
• CMS is proposing the RUC-recommended work RVUs: 10.97 for 15X19, 0.59 for 15X20, 11.28 for 15X21, and 0.98 for 15X22. 

Proposed Revisions to Remote Monitoring Services

With the recent establishment of remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) code families, CMS continues to refine reimbursement for virtual care. For CY 2027, the agency proposes several policy shifts to ensure these services are integrated into longitudinal care:

1. Established patient requirement: Proposing that RTM services be restricted to patients with an existing clinical relationship with the practitioner.
2. Initiating visit mandate: Requiring a separately reportable encounter to trigger the onset of either RPM or RTM service cycles.
3. Staffing limitations: Proposing that payment be limited to services performed by direct clinical staff employed by the billing practice, excluding contracted third-party entities.
4. Valuation updates: Reassessing the underlying resource costs and PFS valuation for these monitoring families.

Furthermore, CMS has solicited feedback on the potential bundling of existing RPM and RTM CPT codes into four new HCPCS G-codes designed to streamline remote care reporting.

Proposed Updates to Telehealth Flexibilities

Consistent with the Consolidated Appropriations Act (CAA) 2026, CMS is proposing to extend core telehealth flexibilities to ensure continued virtual access and defer in-person requirements.

Key policy shifts include:

• Extension of waivers through December 31, 2027, which eliminate geographic restrictions, broaden acceptable originating sites, and maintain expanded practitioner eligibility for virtual care delivery.
• Maintenance of audio-only service authorizations and continued suspension of in-person visit mandates for behavioral health encounters until December 31, 2027.
• Introduction of specialized HCPCS codes (GAPC1, GAPC2, GSMAS, GSLPP, GADV1) and descriptor revisions for G0508 and G0509 to align with contemporary clinical workflows.
• Establishment of new billing modifiers (BB and BC) for services conducted via virtual platforms, effective January 1, 2027, with technical guidance hosted on the CMS resource site.

Proposed Quality Payment Program (QPP) and MIPS Updates

CMS is proposing further refinements to the Quality Payment Program (QPP) for CY 2027, including updates to both MIPS and Advanced APMs. These policy shifts aim to synchronize reporting requirements with clinical outcomes and broader population health objectives. or wound care clinicians, these changes emphasize streamlined participation, clinical relevance, and value-driven reimbursement. 

Evolution toward MIPS Value Pathways (MVPs)

• CMS outlines a strategic transition to phase out traditional MIPS by the CY 2029 performance period / 2031 payment year, positioning MVPs as the primary participation framework for clinicians.
• Advanced APM incentives:
• Under the proposed framework, practitioners attaining Qualifying APM Participant (QP) status via an Advanced APM would remain exempt from MIPS reporting mandates and associated payment adjustments.
• Effective with the 2024 performance cycle (2026 payment year) and beyond, CMS reaffirms that QPs will receive a 0.75% higher conversion factor compared to non-qualifying practitioners.
• Proposed MVP updates for 2027 include:
• Establishment of three additional MVPs - Diabetic Disease, Hospitalist, and Hypertension—focused on chronic condition management and preventive care.
• Integration of MIPS core measures across all MVP specialty sets.
• Proposed updates to the Podiatry MVP ()
• The Podiatry MVP, effective since CY 2026, focuses on meaningful outcomes in chronic conditions, foot and ankle care, and wounds/ulcers.
• Key quality measures include neuropathy and footwear assessment, compression for venous leg ulcers, diabetic foot-ulcer off-loading, ulcer healing or closure, referral-loop closure, falls planning, tobacco screening, blood-pressure follow-up, and surgical-risk communication.
• It also includes improvement activities such as care coordination, longitudinal management of high-risk patients, practice-wide quality improvement, and use of Qualified Clinical Data Registry (QCDR) data.
• Two QCDR measures - remote-monitoring off-loading and chronic-wound outcome monitoring - are proposed for removal because of low adoption and absent benchmarks after two consecutive MIPS years.

For wound care clinicians, this policy shift underscores the growing importance of value-based participation. In addition, joining an Advanced APM could yield payment advantages and reduce administrative burdens under MIPS, particularly as CMS continues to evolve the Quality Payment Program to better reward high-quality, patient-centered care. 

Proposed Revisions to Traditional MIPS

• For the 2027 performance cycle, CMS proposes maintaining existing performance category weights:
• Category Weights:
• Quality: 30%
• Cost: 30%
• Promoting Interoperability: 25%
• Improvement Activities: 15%
• Quality performance updates:
• Refining the quality measure inventory to 180 total measures, introducing 10 new metrics while removing 20 topped-out measures and applying substantive revisions to 43 others.
• Phasing out the “high-priority” designation in favor of a mandate to report a MIPS core measure over a traditional outcome measure.
• Improvement activities:
• Proposal to add 6 new activities, modify 5, and remove 11, alongside the introduction of an “Advancing Health and Wellness” subcategory focused on nutrition and lifestyle-based disease prevention.
• New activities prioritize care coordination and preventive healthcare interventions.

Additional Proposals to Watch

• Behavioral Health Policy Enhancements: Behavioral‑health reimbursement continues to evolve with renewed emphasis on access and integration. Key proposals for CY 2027 include:
• Adjusted work RVUs for time‑based psychotherapy and collaborative care services, with revaluation to better capture psychiatric and care‑manager labor contributions.
• Increased valuation for the Behavioral Health Care Manager clinical labor type (L057B) from $0.57 to $0.70 per minute, recognizing the care coordination role in mental‑health and substance‑use treatment, including opioid‑use disorder (HCPCS G2086–G2088).
• Continued parity between telehealth and in‑person mental‑health visits in RHCs and FQHCs, with suspension of in‑person requirements through December 31, 2027.
• Ambulatory Specialty Model (ASM): CMS proposes refinements to this mandatory five‑year payment model (2027–2031) designed to assess whether linking specialist accountability for quality and total cost of care for heart failure and low back pain can improve outcomes and reduce costs. Key proposals include:
• Performance‑based payment adjustments across four categories - quality, cost, improvement activities, and Promoting Interoperability - with modifiers ranging from ±9 percent at program launch to ±12 percent in later years.
• Collaborative Care Arrangements (CCAs): Formalized coordination between specialists and primary care clinicians to support longitudinal chronic condition management.
• Administrative updates: clarifying definitions for ASM beneficiary and dual‑eligible proportion, introduction of a rural scoring adjustment, and exceptions for clinicians undergoing specialty or identifier changes.
• The model aims to strengthen communication with primary care, support chronic disease prevention, and promote integration of specialty care workflows that may later inform value‑based initiatives relevant to wound management 
• Practice Expense (PF) Reform: Shift toward auditable, objective cost data and elimination of outdated PE per hour benchmark methodology.
• Global Surgery Transparency: Publication of a public file showing imputed RVUs for 10‑ and 90‑day global codes to support valuation accuracy
• Shared Medical Appointments: CMS proposes codes for group‑based preventive visits targeting chronic conditions, aligning with wellness and lifestyle models
• Advance Care Planning (ACP): Two new HCPCS codes (GACP1, GACP2) for clinical staff‑directed time, while CPT 99497/99498 remain for practitioner‑provided time
• DSMT and MNT: Diabetes Self-Management Training (DSMT) and Medical Nutrition Therapy (MNT) would become separately payable preventive services under RHC all-inclusive rate structures.
• Mental health telehealth flexibilities extended through December 31, 2027, consistent with the Consolidated Appropriations Act (CAA) 2026.

Resources

Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule:

• Federal Register
• Fact Sheet