What to Know
- The proposed 2027 MPFS could reshape who gets paid, who much, and for what work.
- Some providers could see meaningful gains while others face unexpected compensation pressure.
- The organizations that model these changes now will be better position to adapt when the final rule arrives.
As discussed in our recent update, CMS issued the Medicare Physician Fee Schedule (MPFS) on July 14, 2026, laying the groundwork for potential implications on provider compensation and medical group revenue. It is important to note that because CMS is mandated to remain budget neutral, the changes outlined are projected to be budget neutral; however, compensation and revenue implications will vary significantly across specialties and depending on an organization’s mix of physicians and advanced practice providers (APPs).
Below we’ve summarized the top three changes we’re watching, as well as some anticipated implications. It is important to note that these changes are not final, and CMS is accepting commentary before finalizing for implementation beginning January 1, 2027 (deadline for comments is September 14, 2026).
A Slow Start for G2211
Originally proposed in the 2021 MPFS final rule but delayed until 2025, the G2211 code was intended to better capture the resource costs associated with longitudinal care relationships between clinicians and patients. At its launch, CMS projected that the G2211 code would be billed in 38% to 54% of eligible new and established evaluation and management (E&M) codes, depending on patient mix. Based on the current MPFS, an additional 0.33 WRVUs would be added to the services provided; however, according to ECG’s analysis, the utilization of the code has been underwhelming.
As a potential fix, CMS has proposed replacing the G2211 code with two new modifiers: one for all provider organizations (MOD1) and another for hospitals participating as accountable care organizations (MOD2). MOD1 and MOD2 would apply a 16% and 32% premium to base E&M codes, respectively.
Based on a comparison of the current structure, the implementation of these modifiers could result in an overall increase in production for clinicians with moderate-to-high-complexity patient panels, as shown below.
| E/M CPT Code | E/M WRVUs |
2026 G2211 Value (0.33 WRVUs) |
Proposed "MOD1" Value (16% Increase) |
Variance (%) |
Proposed "MOD2" Value (32% Increase) |
Variance (%) |
|---|---|---|---|---|---|---|
| 99202 | 0.93 | 1.26 | 1.08 | -14% | 1.23 | -3% |
| 99203 | 1.60 | 1.93 | 1.86 | -4% | 2.11 | 9% |
| 99204 | 2.60 | 2.93 | 3.02 | 3% | 3.43 | 17% |
| 99205 | 3.50 | 3.83 | 4.06 | 6% | 4.62 | 21% |
| 99211 | 0.18 | 0.51 | 0.21 | -59% | 0.24 | -53% |
| 99212 | 0.70 | 1.03 | 0.81 | -21% | 0.92 | -10% |
| 99213 | 1.30 | 1.63 | 1.51 | -7% | 1.72 | 5% |
| 99214 | 1.92 | 2.25 | 2.23 | -1% | 2.53 | 13% |
| 99215 | 2.80 | 3.13 | 3.25 | 4% | 3.70 | 18% |
Typically, the highest users of the G2211 code are family medicine and internal medicine physicians, and, based on CMS’s valuation of the codes, these physicians are expected to see approximately a 1% increase in WRVUs. However, it raises the question of whether market utilization of either proposed modifier will match the underwhelming adoption of the G2211 code.
To Bundle or Not to Bundle: Maternity Services
As we discussed recently, the American Medical Association deleted the global CPT codes associated with maternity care services, as advocated for by the American College of Obstetricians and Gynecologists (ACOG). However, in a move that surprised many, CMS has proposed an alternative set of “G-codes” set to replace the bundled maternity codes. For example, the current 59400 code would be replaced with GMAT1 and retain the same 37.00 WRVUs.
The introduction of these codes has created significant market uncertainty as hospital and health system leaders try to determine whether this is a permanent replacement for the global code or a Band-Aid to assist in the eventual transition to unbundled obstetric services.
If CMS decides to unbundle codes, and a single physician provides all prenatal, labor, delivery, and postpartum services, it is unlikely there will be a material impact on that physician’s production under either model. However, modern care teams typically include other providers (e.g., APPs, midwives) in addition to physicians, so the unbundled methodology could lead to more substantial changes based on an organization’s global WRVU attribution methodology.
As an example, ECG recently partnered with a large health system on the West Coast to analyze the impacts of unbundled codes on the status quo. When comparing WRVU production under the current MPFS versus the proposed unbundled maternity methodology, the organization would realize only a small change (i.e., less than 0.5%), but at the provider level, the impacts were much more profound.
| Provider Type | Variance |
|---|---|
| Physician | -17% |
| Midwife | 25% |
| Physician Assistant | 92% |
| Nurse Practitioner | 136% |
| Grand Total | <1% |
In this case, under unbundled maternity codes, physician WRVUs would drop by nearly 17%, which, depending on the structure of the compensation plan, could have significant impacts on an individual physician’s compensation.
Closing the Gap on the Overlap: Adjustment to Global Procedures and Overlapping Services
Finally, for surgeries billed under a global procedure code, CMS is proposing a change to its methodology that will likely affect reimbursement. In general, under this proposed change, CMS would reimburse 100% for the most expensive service (such as a global surgery procedure), and the less expensive E&M visit or surgical procedure(s) performed by the same physician or a physician in the same practice would be reimbursed at 50%. An example calculation is provided below.
| Service | Current Methodology | Proposed Change | Variance |
|---|---|---|---|
| Procedure (higher valued service) | $400 | $400 | $0 |
| E/M Visit | $130 | $65 | ($65) |
| Total Payments | $530 | $465 | ($65) |
While this change would be limited to outpatient or office-based services and reimbursement, its implications may be felt across multiple procedure-based specialties, including:
- Dermatology.
- Ophthalmology.
- Gastroenterology.
- Orthopedics.
- General surgery.
While compensation may not be directly impacted for WRVU-based production models, the reduction further disconnects reimbursement and compensation. For collections-based compensation models or independent practices, this change could result in reduced Medicare revenue—and consequently, reduced compensation.
Where to Go from Here
Until the rule is finalized, organizations must invest in reviewing these changes and analyzing the potential impacts across compensation and payer contracts.
While many organizations will likely choose to replace the global codes with the new G-codes, there may be financial and care team benefits to adapting the ACOG recommendations. Further, the changes may also push leaders to review their care teams to ensure physicians and APPs are performing at the top of their license and better align services with CMS’s reimbursement priorities.
ECG is currently evaluating the impact of the proposed MPFS relative to the current MPFS using CPT-level data submitted in the ECG 2026 Physician and APP Survey. A subsequent article will be provided based on market benchmark impacts.
