Big Changes Coming to Nursing Facility Billing & Care Regulations in CY 2027
The Centers for Medicare & Medicaid Services (CMS) released its CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), bringing major shifts for clinicians and facilities:
- POS 31 & POS 32 Rate Equalization: CMS proposes setting equal practice expense (PE) RVUs for CPT codes 99304–99310, 99315, and 99316. Under this proposal, Part A stay visits (POS 31) gain 12–15%, while Part B visits (POS 32) adjust down slightly (0.9%–3.8%).
- Conversion Factor Drop: Due to expiring updates, the conversion factor is set to decrease by 1.68% for non-APM clinicians ($32.8409) and 1.19% for APM participants ($33.1693).
- G2211 Phase-Out & Replacement: CMS proposes replacing G2211 with new 16% and 32% modifiers for office/home visits — while keeping nursing facility visits excluded.
- Tighter RPM & RTM Rules: Remote monitoring will now require an initial face-to-face visit, apply to established patients, and ban third-party contracted monitoring companies (must be direct employees).
- Advance Care Planning Recoding: CPT 99497/99498 will be restricted to clinician-only time, while new G-codes (GACP1 & GACP2) cover staff-delivered care.
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