Let’s Take A Look
Our partners at the Center for Connected Health Policy have summarized the new Change Request issues by CMS:
“On July 14, 2026, the Centers for Medicare and Medicaid Services (CMS) released their proposed CY 2027 Physician Fee Schedule (PFS). The PFS is the vehicle used by CMS to make changes for the upcoming year within the Medicare program. At this time, these changes are only proposals and the public has until September 14, 2026 to provide comments. The PFS proposals are usually finalized later in the year, often this occurs sometime in November of each year. Unless otherwise stated, the finalized changes will go into effect on January 1, 2027. Below is a brief summary of each proposal related to telehealth below.
Please note that all page references are linked to the unpublished version of the PFS.”
CY 2027 PROPOSALS
Eligible Telehealth Services List (Page 61)
Each year, CMS typically adds one or more services to the current eligible telehealth services list, either of their own accord or as a result of a suggestion from the public that CMS has found meets the criteria to be added to the list. As a reminder, under Medicare, practitioners will only be reimbursed for specific services that are provided via telehealth. This year, CMS notes that it did not receive any suggestions from the public for services to be placed on the list, however, CMS has made several of their own recommendations for new service codes, including:
|
CODE |
DESCRIPTION |
|
GACPI |
Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), first 20 minutes of clinical staff time with the patients, family member(s), directed by a treating physician or other treating qualified health care professional. |
|
GACP2 |
Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), each additional 20 minutes with the patient, family member(s), directed by a treating physician or other treating qualified health care professional (List separately in addition to code for primary procedure). |
|
GSMAS |
Voluntary, group-based medical session involving multiple patients with common medical condition(s), receiving medical care in any group setting; billed and led by a physician or qualified nonphysician practitioner and may include services provided by other qualified healthcare professionals, clinical staff, or auxiliary personnel under the direction of the supervising physician or other practitioners. Session integrates group education, counseling, and peer support with individualized patient clinical assessment and care, 2-10 patients, billed once per patient, per session. |
|
GSLPP |
Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual; for the pediatric population up to age 18 or 21. |
|
GADV1 |
Office or other outpatient evaluation and management service(s) for the diagnosis and treatment of vaccine adverse effects, new or established patient; each 15 minutes personally performed by the physician or qualified healthcare professional. |
|
99202 |
Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. When using time for code selection, 15-29 minutes of total time is spent on the date of the encounter. |
|
99203 |
Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using time for code selection, 30-44 minutes of total time is spent on the date of the encounter. |
|
99204 |
Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using time for code selection, 45-59 minutes of total time is spent on the date of the encounter. |
|
99205 |
Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using time for code selection, 60-74 minutes of total time is spent on the date of the encounter. |
|
99211 |
Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional. |
|
99212 |
Office or other outpatient visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. |
|
99213 |
Office or other outpatient visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using time for code selection, 20-29 minutes of total time is spent on the date of the encounter. |
|
99214 |
Office or other outpatient visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using time for code selection, 30-39 minutes of total time is spent on the date of the encounter. |
|
99215 |
Office or other outpatient visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using time for code selection, 40-54 minutes of total time is spent on the date of the encounter. |
|
99341 |
Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. When using total time on the date of the encounter for code selection, 15 minutes must be met or exceeded. |
|
99342 |
Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded. |
|
99344 |
Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded. |
|
99345 |
Home or residence visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using total time on the date of the encounter for code selection, 75 minutes must be met or exceeded. |
|
99347 |
Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. When using total time on the date of the encounter for code selection, 20 minutes must be met or exceeded. |
|
99348 |
Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded. |
|
99349 |
Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded. |
|
99350 |
Home or residence visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded. |
Additionally, as a result of questions received from the public, CMS is also proposing to clarify the elements of two codes by revising their formal descriptors. The proposed changes of the descriptors for these two codes include:
|
CODE |
CURRENT DESCRIPTION |
PROPOSED CHANGES |
|
G0508 |
Telehealth consultation, critical care, initial physicians typically spend 60 minutes communicating with the patient and providers via telehealth. |
Telehealth consultation, critical care; first 30 to 74 minutes. |
|
G0509 |
Telehealth consultation, critical are, subsequent physicians typically spend 50 minutes communicating with the patient and providers via telehealth. |
Telehealth consultation, critical care, each additional 30 minutes (list separately in addition to code for primary service). |
CMS notes that they are also seeking comments on whether to provide payment for physician-patient clinical trial discussions and whether it should be available via telehealth. The potential code would be defined as a minimum of 20 minutes of physician or qualified health professional’s time spent on clinical trial counseling. (Page 215)
Extension of the Telehealth Waivers & New Modifiers (Page 62)
In the CY 2027 PFS CMS proposes the implementation of several directives that were previously included in the Consolidated Appropriations Act of 2026 (CAA 2026). The CAA 2026 extended the telehealth waivers expiration date to December 31, 2027, and also delayed the required prior in-person visit for mental health services (if the visit does not qualify for certain exceptions) for both eligible practitioners, as well as for federally qualified health centers (FQHCs) and rural health clinics (RHCs) when they are using technology to provide these services. CMS has proposed changing regulations to reflect these new dates to show that permanent policies will go back into effect on January 1, 2028.
Additionally, the CAA 2026 called for CMS to create new modifiers to capture when a practitioner provides services via telehealth through a third-party platform that the practitioner has either a contract or payment arrangement in place with. The proposed two modifiers are BB and BC.
Direct Supervision Via Telehealth (Page 65)
In the final CY 2026 PFS, CMS permanently allowed teaching physicians to have a virtual presence in all teaching settings, however when in clinical instances, supervision provided via live video can only be conducted via a three-way telehealth visit, with each party in a separate location. Due to public comments received that note it should be taken into consideration the fact that there may be occasions where the teaching physician and resident are in the same physical location (thereby not meeting the requirement that each party be in a different location), CMS is now proposing a modification that would allow the teaching physician to bill for services involving the resident when either the resident or the teaching physician is in the same physical location as the patient. CMS currently regards “physical location” as meaning in the same room as the beneficiary, however CMS is still seeking comments on this aspect. It is important to highlight that this situation would only apply to services that are on the eligible Telehealth services list for Medicare. Appropriate documentation would be required.
Remote Physiologic Monitoring & Remote Therapy Monitoring (Page 149)
Remote Physiologic Monitoring (RPM) and Remote Therapy Monitoring (RTM) are the terms CMS uses for “two code families that describe certain remote monitoring services”. Many generally refer to these as remote patient monitoring services. Over the years, CMS has both added to and refined how and when RPM and RTM services may be used to ensure reimbursement. For 2027, CMS is again proposing additional refinements to these services. Specifically, CMS is proposing that:
-
RTM services are to be furnished only for established patients (this requirement already existed for RPM).
-
Practitioners must furnish a separately reportable initiating visit in association with the onset of RPM or RTM services. The RPM and RTM services must be initiated by the billing practitioner during a face-to-face (may be in-person or via telehealth) visit. If the visit is not face-to-face or not separately payable by Medicare, it would not satisfy this requirement. If RPM/RTM is not discussed with the patient during the initiating visit, it would not count towards this requirement. The initiating visit can be billed separately.
-
CMS is proposing to only allow payment RPM/RTM services when it is provided by clinical staff employed by the practice. The clinical staff must be a direct employee of the practitioner or practitioner’s practice. Clinical staff and beneficiary need not be physically on-site. This would mean that employees of a third-party contractor would not qualify for reimbursement.
-
For codes 99473, 99445, 99454, 989-98978, 98984-98986, CMS is proposing crosswalks to other codes as certain costs may not be captured.
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For codes 99470, 99457-99458, 98977-98981, CMS is proposing to eliminate practice expense (PE) inputs as they believe certain costs have already been captured in the work relative value unites (RVUs).
CMS is also soliciting a litany of comments/feedback on a variety of suggestions around RPM and RTM beyond just the aforementioned proposals. These comment solicitations include:
-
The administrative burden of the current coding structure for the remote monitoring family code.
-
The bundling of CPT codes 99453, 99445, 99454, 99091, 99470, 99457, 99458, 98975, 98984, 98976, 98985, 98977, 98986, 98978, 98979, 98980, and 98981. Instead of these individual codes, there could be creation of new codes for initial set up and monthly monitoring and set up.
-
The creation of four new HCPCS codes, their valuation and whether these codes should be implemented for FQHCs and RHCs:
|
CODE |
DESCRIPTION |
|
GRPM1: |
RPM initial set-up and patient education. |
|
GRPM2: |
Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), per calendar month, including:
|
|
GRTM1: |
RTM initial set-up and patient education. |
|
GRTM2: |
Remote monitoring of therapeutic parameter(s) (e.g., therapy adherence, therapy response, digital therapeutic intervention), per calendar month, including:
|
Other Items
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The proposed Originating Site Fee for CY 2027 is $32.65 (Page 67)
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CMS proposes increasing the value of several codes for the Psychiatric Collaborative Care Model (CoCM) and the Advanced Primary Care Model (APCM) Behavioral Health Integration (BHI). Specifically, codes 99492-99494, G2214, G0568, G0569, G2214, G2086 – G2088. (Page 163)
