The CY 2027 Medicare Proposed Rule: What Coders Should Watch

On July 14, 2026, CMS released the calendar year 2027 Physician Fee Schedule proposed rule (CMS-1848-P), with comments due September 14, 2026. Proposed rules aren’t final — policies routinely change before the fall final rule — but they’re the best preview of what coding and billing teams will implement in January. Here’s the coder’s-eye summary.

Telehealth: extended flexibilities and two new modifiers

Congress already did some of the work: the Consolidated Appropriations Act, 2026 extended the geographic and originating-site waivers for Medicare telehealth through CY 2027, and the proposed rule codifies those extensions. The telehealth originating-site facility fee (Q3014) would rise modestly to $32.65.

The changes coders will feel most directly are two new claim modifiers mandated by the CAA and effective January 1, 2027:

Modifier BB — telehealth services furnished through certain third-party virtual platform arrangements
Modifier BC — telehealth services furnished incident-to another professional’s service

Neither modifier affects payment; both exist so CMS can see, at the claim level, who is actually delivering telehealth and through what arrangements. Operational guidance is promised on the CMS website rather than spelled out in the rule, so expect a scramble to define internal rules for when each applies. Start inventorying your telehealth arrangements now — if any involve platform vendors or incident-to billing, you’ll need modifier logic in your claim workflows by January.

New G-codes joining the telehealth list

CMS proposes five new HCPCS G-codes and would add them to the Medicare Telehealth Services List: GACP1 and GACP2 for advance care planning furnished by clinical staff under practitioner direction, GSMAS for group/shared medical appointments (2–10 patients), GSLPP for pediatric speech-language treatment, and GADV1 for evaluation of vaccine adverse effects. The clinical-staff ACP codes are notable — they create a billing path for work that previously had none, and CMS is seeking comment on whether a combined practitioner-plus-staff code would fit practice better.

Remote monitoring: transparency requirements coming

Building on the 2026 RPM code expansion, CMS proposes requiring practitioners to disclose when third-party vendors furnish all or part of remote physiologic or therapeutic monitoring services billed to Medicare. The agency frames it as program integrity: it wants visibility into who actually performs the monitoring behind the claims. Practices using RPM vendors should anticipate new reporting obligations and review vendor contracts against whatever documentation standard the final rule sets.

Payment mechanics worth a glance

The proposed conversion factors tick downward for 2027, and CMS proposes a significant modernization of practice-expense RVU methodology — phasing out reliance on specialty survey data that’s nearly two decades old and reallocating indirect costs. Coders don’t set rates, but valuation shifts change which services draw payer and audit scrutiny, and specialty societies will be commenting loudly through September.

What to do between now and the final rule

Inventory telehealth arrangements against the BB/BC modifier definitions and flag ambiguous cases for compliance review.
Flag the new G-codes for any service lines doing ACP, group visits, pediatric speech, or vaccine clinics — these are new revenue paths if finalized.
Review RPM vendor relationships and prepare for disclosure requirements.
Comment if affected. The September 14 deadline is real leverage; CMS does modify proposals in response to specific, operational comments.
Calendar the final rule — typically issued around November 1 — and plan January system updates then, not in December.

Proposed rules reward the teams that read them early. The BB/BC modifiers alone justify an hour with the telehealth section this month.

This summarizes proposed — not final — policy as of August 2026. Verify all provisions against the final rule and official CMS guidance before implementation.

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Originally Published On: Medical Coding News

Photo courtesy of: Getty Images

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