CMS 2027 Physician Fee Schedule Proposal Could Reshape Reimbursement for Podiatry and Wound Care

The proposed 2027 Medicare Physician Fee Schedule includes changes to Modifier 25 reimbursement, conversion factors, and practice expense methodology that could have significant implications for podiatrists providing wound care. With the rule still in the proposal stage, one thought leader reminds clinicians that they have until September 14, 2026, to submit comments to CMS.

Key Takeaways

• CMS proposes reducing payment for certain same-day E/M services billed with Modifier 25, a policy that one thought leader expects to have a particularly large negative impact on certain specialties.
• The Modifier 25 proposal comes alongside broader physician reimbursement pressures, including lower 2027 conversion factors and changes to practice expense methodology that could affect office-based care.
• The proposal is not final. Clinicians and professional organizations can submit comments on CMS-1848-P through September 14, 2026.

Proposed Modifier 25 Policy Could Affect Same-Day Wound Care

The Centers for Medicare & Medicaid Services (CMS) proposed several Medicare payment policy changes for calendar year (CY) 2027 that could have important implications for podiatrists and wound care professionals, according to an August 17 Clinician Commentary in Podiatry Today by Eric J. Lullove, DPM, CWSP, MAPWCA, FFPM RCPS (Glasg).¹

Among the most consequential is a proposed change he cites affecting evaluation and management (E/M) services reported with Modifier 25. Under the proposal, when a separately identifiable office or outpatient E/M service is provided by the same physician—or a physician in the same practice—on the same day as a procedure with a 0-, 10-, or 90-day global period, the most expensive service would be paid at 100%, while each additional service would be paid at 50%.¹

The article notes that CMS previously considered a similar policy in the proposed CY 2019 Physician Fee Schedule but did not finalize it.¹ The agency has continued to raise concerns about potential duplication in payment for same-day services.

Why Podiatry Could See a Disproportionate Impact

According to the article, Dr. Lullove expects the Modifier 25 proposal to have a large negative impact on certain specialties, while most other specialties could experience a small increase as relative value units are redistributed under budget-neutrality requirements.¹

For those involved in wound management, the implications could be particularly relevant because patients frequently present with multiple clinical needs during a single encounter. The article gives the example of an older patient with diabetes who presents for routine nail and callus care but is found to have a new ulceration. Another example involves a patient requiring wound debridement who also presents with a separate problem requiring evaluation and workup.¹

Lullove argues that addressing these issues during the same encounter can support efficient, patient-centered care and preserve access for patients who otherwise might need to return for another appointment. Under the proposed reimbursement approach, however, payment for certain same-day services could be substantially reduced.

Conversion Factor and Practice Expense Changes Add Reimbursement Pressure

Modifier 25 is not the only payment issue highlighted in the proposal. The temporary 2.5% conversion factor increase for CY 2026 will no longer apply in 2027, creating an additional reimbursement change before other adjustments are considered.¹

After statutory updates and budget-neutrality calculations, the proposed rule would decrease the qualifying alternative payment model (APM) conversion factor by 1.19% and the nonqualifying conversion factor by 1.68% for CY 2027 compared with CY 2026, according to the article.¹

The proposal also includes changes to the practice expense methodology, which influences Medicare reimbursement for office-based and outpatient surgical services. Taken together, these policies could create additional financial pressure for practices delivering podiatric and wound-related services.¹

CMS Public Comment Period Runs Through September 14

Importantly, these policies remain proposals rather than finalized Medicare payment rules.

CMS opened a 60-day public comment period that ends September 14, 2026. Comments submitted through Regulations.gov under file code CMS-1848-P become part of the official rulemaking record, and CMS must review and respond to substantive comments before issuing the final rule.¹

The article encourages impacted specialists to provide specific clinical examples illustrating how the proposed Modifier 25 payment reduction could affect patients with diabetes, wounds, neuropathy, and vascular disease. It also recommends engaging congressional representatives and supporting state and national professional organizations preparing formal responses.1

For wound care professionals, including podiatrists, the proposal therefore represents both a potential reimbursement change to watch and an active opportunity to provide CMS with information about how Medicare payment policy may affect access to coordinated, same-day care for medically complex patients.¹

Reference

1. Lullove EJ. What the proposed CMS 2027 Physician Fee Schedule means for podiatry. Podiatry Today. Published August 17, 2026. Accessed August 17, 2026. https://www.hmpgloballearningnetwork.com/site/podiatry/blog/what-proposed-cms-2027-physician-fee-schedule-means-podiatry