What the Proposed CMS 2027 Physician Fee Schedule Means for Podiatry

The proposed CMS CY 2027 Physician Fee Schedule includes several payment policy changes that could significantly affect podiatric practice, particularly surrounding Modifier 25 billing and physician reimbursement. Dr. Eric Lullove reviews the proposal, explains why CMS identifies podiatry as one of the specialties most affected, and discusses why participation during the public comment period matters.

Key Takeaways

• The proposed CMS CY 2027 Physician Fee Schedule includes a reduction in payment for certain same-day E/M services billed with Modifier 25, a change projected to disproportionately affect podiatry.
• Beyond the Modifier 25 proposal, physician payment would also be affected by changes to the conversion factor and practice expense methodology, with potential implications for office-based podiatric care.
• Because the rule remains in the proposal stage, podiatrists have an opportunity to review the proposal and submit comments before the September 14, 2026 public comment deadline.

Every year, the Centers for Medicare and Medicaid Services (CMS) release a proposed Physician Fee Schedule (PFS), and every year I see the same thing happen in our profession. A few dozen podiatrists read the summaries. A smaller number understand the implications. And an even smaller number—a vanishingly small number—actually do anything about it. Then the rule is finalized, the cuts take effect, and we spend the following 12 months complaining about a policy we had a legal right to shape and chose not to.

The CY 2027 Physician Fee Schedule proposed rule, released July 14, 2026, is the year we cannot afford to repeat that pattern.¹ The following sections outline the provisions likely to have the greatest impact on podiatry and why participation in the public comment period is an important part of the rulemaking process.

What Is Actually on the Table

Two provisions deserve every podiatrist's attention.

The first is the Modifier -25 reduction. Under the proposal, when a separately identifiable office or outpatient evaluation and management (E/M) visit is furnished by the same physician (or a physician in the same practice) on the same day as a 0-, 10-, or 90-day global procedure, the most expensive service is paid at 100% and every other service that day is paid at 50%.¹ CMS is explicitly proposing to reduce payment for the same-day E/M-plus-procedure combination. This is not new thinking on the agency's part—a similar proposal appeared in the CY 2019 PFS proposed rule and was not finalized at the time, though CMS noted it continued to believe the current methodology likely duplicates payment.² This is their return attempt.

The second provision is the broader payment cut in which the Modifier -25 change is embedded.¹ The temporary 2.5% conversion factor increase provided for CY 2026 no longer applies in CY 2027, which under current law produces a 2.5% reduction relative to 2026 before other adjustments. After the statutory updates and budget-neutrality math, the rule decreases physician payment by reducing the qualifying-APM conversion factor by 1.19% and the non-qualifying conversion factor by 1.68% for CY 2027 compared to CY 2026.¹ Alongside this sit changes to the practice expense methodology, which govern how much Medicare pays for the office-based, outpatient surgical work that defines so much of podiatric practice.

Why the Proposal Could Disproportionately Affect Podiatry

The Modifier -25 proposal is not a broad, evenly distributed policy. CMS expects it to have a large negative impact on otolaryngology, dermatology, and podiatry, with a smaller effect on hand surgery, physician assistants, and colon and rectal surgery, while most other specialties would see a small increase from the redistribution of those Relative Value Units (RVUs).³ Read the second half of that sentence carefully: the RVUs stripped from us get redistributed to other specialties. This is budget-neutral. Our loss is quite literally someone else's gain.

The proposal reaches any physician who routinely bills Modifier -25 alongside procedures with global periods, and in my observation, no specialty bills that combination more naturally than ours. Consider the elderly patient with diabetes who arrives for routine nail and callus care and is found to have a new ulceration or the patient with a wound that needs debridement and a separate, unrelated problem requiring workup. Multiplicity on a single date of service is not a billing trick in podiatry—it is efficient, access-preserving, patient-centered care. The proposed rule penalizes exactly that.

Why the Public Comment Period Matters

Regardless of one's view of the proposal, the current public comment period represents the primary opportunity for clinicians to provide feedback before the rule is finalized.

There is a 60-day public comment period, and it closes on September 14, 2026. During this window, comments submitted to regulations.gov under file code CMS-1848-P become part of the official rulemaking record. CMS is legally obligated to review and respond to substantive comments before finalizing the rule. This is not symbolic. Comment volume and comment quality genuinely shape Final Rules—well-documented clinical objections force the agency to justify, modify, or withdraw proposals it would otherwise finalize by default.

As with previous rulemakings, specialties that submit detailed clinical feedback may provide additional information for CMS to consider during that process. When the Final Rule is written, the specialties that organized may get the carve-outs, the phase-ins, and the reconsiderations. The specialty that stayed home gets the rule as proposed.

The same logic governs Congress. The conversion factor trajectory—the annual ritual of cuts driven by statutory budget neutrality and the sunsetting of temporary patches—is fundamentally a legislative problem, not a regulatory one. This proposal is likely to renew congressional discussion of long-term physician payment reform, particularly as Medicare payment updates continue to lag the Medicare Economic Index. That conversation is happening whether or not we are in the room. A congressperson who receives 200 letters from podiatrists in the district treats this as a live issue. A congressperson who receives zero treats it as settled. Members of Congress prioritize what their constituents raise. If we never raise it, we have decided—by omission—that it does not matter to us.

That is what "silence is a vote" means. When CMS tallies the record and Congress reads its mail, an absent podiatry profession is not neutral. It is counted as acquiescence. Every comment we don't file is a comment for the rule as written. Every call we don't make is a signal that our members can absorb the cut.

What Every Podiatrist Should Do Before September 14

Clinicians who wish to provide feedback have several avenues available before the comment period closes, which takes less time than most of us spend on a single prior authorization appeal.

Submit a comment on CMS-1848-P at regulations.gov. It does not need to be a legal brief. A few paragraphs describing, in clinical specifics, what a 50% reduction on same-day services does to your diabetes and wound care patients—the access consequences, the workflow distortion, the choice between doing double work for half pay or forcing a vulnerable patient back for a second appointment—carries real weight precisely because it is real. Agency reviewers respond to concrete clinical harm, not abstraction.

Then contact your House representative and both senators. Name the Modifier -25 proposal. Name the conversion factor cut. Explain that these fall hardest on the specialty that cares for the diabetic, neuropathic, and vascularly compromised patients most at risk of amputation. Ask them to weigh in with CMS and to support physician payment reform.

Support your state and national podiatric organizations as they prepare formal comments and amplify them. A coordinated professional voice and thousands of individual constituent voices are complementary, not redundant.

The Bottom Line

The CY 2027 proposed rule is a serious threat: a Modifier -25 reduction that halves payment for the same-day care that defines podiatric practice, layered on top of a conversion factor cut and practice expense changes that erode office-based surgical reimbursement.¹ But the rule is not final. The record is open until September 14. For the next several weeks, we have something we spend the rest of the year wishing we had—a formal, legally weighted opportunity to change the outcome.

Because the proposal remains open for public comment until September 14, clinicians and professional organizations still have an opportunity to provide feedback before CMS issues the final rule.

Dr. Lullove is the Chief Executive and Medical Officer at the West Boca Center for Wound Healing in Coconut Creek, FL.

References

1. Centers for Medicare and Medicaid Services. Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule. Available at https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule. Published July 14, 2026. Accessed Aug. 5, 2026.
2. Centers for Medicare and Medicaid Services. Proposed Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2019. Available at https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-0. Published July 12, 2018. Accessed Aug. 5, 2026.
3. Holland & Knight. CMS Issues CY 2027 Medicare Physician Fee Schedule Proposed Rule. Available at https://www.hklaw.com/en/insights/publications/2026/07/cms-issues-cy-2027-medicare-physician-fee-schedule-proposed-rule. Published July 20, 2026. Accessed Aug. 5, 2026.
4. American Hospital Association. CMS issues CY 2027 physician fee schedule proposed rule. Available at https://www.aha.org/news/headline/2026-07-14-cms-issues-cy-2027-physician-fee-schedule-proposed-rule. Published July 14, 2026. Accessed Aug. 5, 2026.