2027 Proposed Rule Impacts Coding and Reimbursement
Summary
CY 2027 Medicare Proposed Rule
What It Means for Urology
CMS released the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, 2026. Comments are due September 14, 2026. A second rule, the OPPS/ASC proposed rule (CMS-1850-P), covers hospital payment. Its comment period closed on August 31, 2026. Each item on this page is a proposal, not a final rule. No change starts before January 1, 2027.
The final rule usually comes out in November. PRS rates this rule near average for a proposed rule. One proposal is much worse than the rest: the modifier -25 payment cut. This report starts with that proposal.
Today, Medicare pays the full rate for an E/M visit with modifier -25 on the same day as a procedure. Under the proposal, Medicare pays only the highest-value service at 100 percent. Medicare pays each other same-day service at 50 percent. This includes the E/M visit. The cut applies when the same doctor or group bills the two services on one day. It covers procedures with a 0-, 10-, or 90-day global period.
Urology offices bill many same-day services. Think of a surveillance cystoscopy with a same-day visit. The cystoscopy has the higher value, so the E/M visit gets the cut. Now think of a visit with a same-day PTNS session, catheter change, or injection. The E/M visit has the higher value, so the procedure gets the cut. One of your two services gets half payment each time.
PRS does not agree with the 50 percent number. The usual multiple-procedure cut removes work that two services share. Modifier -25 pays only for E/M work that is separate from the procedure. The two services share almost no work. CMS knows this proposal will get pushback. CMS also asks if 25 percent is a better number.
Private payers watch Medicare. Some payers tried same-day E/M cuts in some states before. A final Medicare cut can open that door wider. This is the top target for comment letters. See the Suggested Comments tab.
The conversion factor is the dollar amount behind each RVU. The 2.5 percent increase from Congress ends after 2026. So the proposed conversion factor decreases. Most doctors get $32.8409, a 1.68 percent decrease. Doctors in a qualifying APM get $33.1693, a 1.19 percent decrease. Congress can still act before January 1.
CMS shows urology at about -2 percent before the conversion factor change. The office side takes the larger hit. That estimate does not include the modifier -25 cut. Office-heavy practices must model a larger decrease. One good item: the efficiency adjustment does not occur in 2027. It returns in CY 2029.
CMS proposes to delete G2211. A new modifier replaces it. The modifier adds 16 percent to the value of the E/M code. ACO doctors get a second modifier that adds 32 percent. Payment then increases with the level of the visit. That is usually good for urology.
One limit stays: you cannot use the new modifier when the E/M visit needs modifier -25. If your pay is based on wRVU production, ask your employer how the new modifier counts in your contract. Ask before January.
CMS accepts the new CPT 2027 structure for the prostate biopsy codes. Most work values stay the same: 55705 (1.88), 55707 (2.63), 55708 (3.39), 55709 (3.23), 55710 (3.81), and 55714 (3.62).
CMS proposes three changes. 55711 decreases from 2.61 to a proposed 2.37, and its facility payment also decreases. 55715, the in-bore add-on for each added lesion, increases from 1.05 to a proposed 1.80. A new add-on code covers each added fusion-targeted lesion. Its CPT number is not set (the rule uses the placeholder 5XX14). The RUC recommended 0.80 for it, but CMS proposes 0.68.
The code words also change. Code selection turns on one fact: did fusion target a specific lesion? Your notes must show the approach, the guidance, and the number of targeted lesions. PRS will give more guidance when the final CPT words come out.
51715 gets good news. CMS proposes to add the bulking agent as a supply cost in the office rate. CMS set the agent cost at $1,175 for each vial. The office value increases about 284 percent. The proposed national office rate is about $1,332.36 with one vial. CMS can also remove the separate L-codes for the agent in this use.
This makes office treatment much easier to afford. CMS also asks if 51715 must go to the RUC. Watch that question.
First, CMS again did not increase the supply prices in 51728 and 51729. This is the second year in a row. The prices were not the problem. CMS said the invoice names did not match its supply codes.
Second, the technical-component values decrease about 5 percent. The total values decrease about 3.8 to 4 percent before the conversion factor. You can win the supply issue. See the second letter on the Suggested Comments tab.
The rule adds hard limits to remote monitoring (RPM and RTM). RTM becomes limited to established patients, like RPM. Both need a face-to-face start visit. Only direct employees of the practice can do the monitoring. Third-party monitoring companies are not allowed. CMS also decreases the values of the set-up and device-supply codes (99453, 99454, 98975, and related codes).
CMS asks about a plan to merge the code families into four bundled G-codes. If a vendor runs your monitoring program, review that model before 2027.
Telehealth stays mostly the same because Congress set the law. You still report Medicare telehealth with the usual E/M codes. The rule adds new virtual-platform modifiers. It also adds G-codes for group medical visits. A group visit has 2 to 10 patients with the same chronic condition (up to 25 in some cases). You can bill for each patient, but each patient needs a note.
Global surgery: CMS stopped the post-op visit data collection. CMS asked about a plan to report 99024 for all follow-up visits. That is not a proposal yet. Practice expense: CMS starts to remove the 2007 survey data from the payment math. Office procedures will re-rank over several years.
Lab: clinical lab fees can decrease up to 15 percent each year through CY 2029. A new SaMS policy moves some software-analysis codes to the fee schedule. MIPS: the urology MVP continues with changes. Q476 (BPH symptom score) and Q481 (BCG timing) change. New measures cover incontinence, surgical risk, and bone density.
The facility rule (CMS-1850-P) has three urology items. First, new code C8014 covers cysto/URS lithotripsy with a suction-enabled ureteral access sheath. Its payment group and status indicator were open for comment. Second, the payment for C9789 decreases from $1,250.50 to a proposed $1,150.50. Third, prior authorization starts for some botulinum toxin codes on July 1, 2027. Bladder chemodenervation (52287) is not on that list.
Hold your 2027 chargemaster changes until the final rules come out.
This rule is not the worst, and it is not the best. It is a bit below average. The modifier -25 proposal causes most of the damage. It is nowhere near the CY 2026 facility hit.
Do four things now. Model your same-day visit volume against the 50 percent cut. Review your wRVU contracts and your vendor monitoring deals. Mark all 2027 numbers as proposed until November. Send comment letters. The next tab shows you where to aim.
Suggested Comments
CY 2027 Proposed Rule
Where to Aim Your Comment Letters
Comments on the rule are due September 14, 2026. Send them at regulations.gov. Use file code CMS-1848-P. Work through your societies (AUA, LUGPA), and also send your own letter. Short letters with real practice data work best. Two letters matter most for urology this year.
Oppose the 50 percent same-day E/M cut (modifier -25)
What CMS proposes: Medicare pays the highest-value same-day service at 100 percent. Medicare pays each other same-day service, with the E/M visit, at 50 percent. CMS also asks if 25 percent is a better number.
Say that the two services share no work. Modifier -25 pays only for E/M work that is separate from the procedure. A 50 percent cut removes work that was never shared.
Say that the shared costs are small. One arrival and one claim save a small amount of staff time only. If CMS keeps a cut, ask for 25 percent or less. Ask CMS to apply it only to practice expense.
Show your own numbers. Pull 12 months of same-day E/M and procedure claims. Apply the 50 percent cut to those claims. Put the dollar and percent effect in your letter. Real numbers from real practices move final rules.
Say that the values already include an offset. The procedure values already include an adjustment for a possible same-day E/M visit. A new cut counts that offset twice.
"We oppose the proposed 50 percent cut for E/M services with modifier -25. Modifier -25 identifies E/M work that is significant and separate from the same-day procedure. The services share no work that a cut can remove. In our practice, this policy decreases payment by [$X / Y%] across [N] necessary patient visits in 12 months. If CMS keeps a cut, limit it to practice expense and do not go above 25 percent."
Fix the urodynamics catheter supply prices (51728/51729)
What happened: a nominator asked CMS to increase the catheter supply prices in 51728 and 51729. The supply codes are SD017 ($35.89 to $74.00), SD027 ($19.35 to $86.80), and SD131 ($2.90 to $25.48). CMS said no for the second year in a row. The prices were not the problem. CMS said the invoice names did not match its supply codes. That is a paperwork problem, and you can fix it.
Close the paperwork gap. Send new invoices. Add a crosswalk table that maps each invoice line to SD017, SD027, or SD131. Use catalog numbers and product names. Add manufacturer letters that state each match.
Show the real costs. State what you pay for each catheter set today. Compare that to the prices in the CMS inputs. Low supply prices push this test out of the office and into more costly locations.
Work together. One strong letter from many practices does more than many weak letters. PRS can help you make the crosswalk.
"We ask CMS to complete the supply repricing for CPT 51728 and 51729. The attached invoices include a crosswalk from each invoice line, by catalog number, to supply codes SD017, SD027, and SD131. Manufacturer letters state each match. This answers the match problem that CMS named. We pay [$X] in supplies for each study, which is much more than the current CMS inputs. Low supply prices put office access to this test at risk."
Fusion biopsy add-on: support the RUC value of 0.80 for the new add-on code. CMS proposes 0.68. Remote monitoring: oppose the employee-only limit, or ask for a transition period. Send device cost data. CMS asked for that data. Bulking agent: if you do 51715, send a short letter that supports the new supply payment.
Send your letter by September 14, 2026, at regulations.gov. Use file code CMS-1848-P. One topic for each letter is fine. Keep it short and specific, and add data. Send a copy to your societies. PRS prepares its own letter on modifier -25. Contact us for help with your numbers or with the crosswalk.