The Centers for Medicare & Medicaid Services (CMS) has released the proposed Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS), outlining potential changes to physician reimbursement, MIPS reporting, and other Medicare payment policies.
While these proposals are not final, they offer an early look at the direction CMS is considering for 2027 and give dermatology practices time to understand what's being discussed before the final rule is issued later this year. Here's what you should know—and what it means for your practice.
Proposed Means Proposed
Before diving into the details, it's important to remember that this rule is exactly that—a proposal.
CMS is currently accepting public comments before issuing the final Physician Fee Schedule later this year. That means the information in the proposed rule may change before it becomes official.
Dermatology providers and practice leaders are encouraged to review the proposed rule and submit feedback to CMS before the September 14, 2026 public comment deadline. Click here to submit your comments.
For now, practices should stay informed, monitor updates, and avoid making significant operational changes until the final rule is published.
Three Key Takeaways for Dermatology Practices
The proposed rule covers hundreds of pages and touches nearly every aspect of Medicare physician payment and quality reporting. While much of it won't directly impact practices until the rule is finalized, several proposals stand out as especially important for dermatology practices to understand. Here are the three biggest takeaways.
1: Medicare Payment Policies Continue to Evolve
The proposal includes updates to physician reimbursement and payment policies that could affect Medicare-participating practices beginning in 2027.
What this means: Based on the proposed 2027 Medicare Physician Fee Schedule conversion factor and other policy changes, CMS estimates that dermatology practices will experience an overall 9% reduction in allowed charges.
This projected decrease is driven in part by the proposed reduction in the Medicare Physician Fee Schedule conversion factor (CF) to $32.84 for qualifying participants, a $0.56 decrease from 2026. Additional reimbursement reductions are expected from the proposed 50% payment reduction for same day E/M visits with procedures as well as proposed revisions to the methodology used to calculate the Practice Expense (PE) component of the total RVU under the Medicare Physician Fee Schedule.
There is, however, some encouraging news. CMS has proposed expanding Medicare coverage for CPT codes 96920, 96921, and 96922 beyond psoriasis to include the treatment of inflammatory and autoimmune skin diseases—a long-awaited and welcome change for dermatology providers and their patients.
While reimbursement details may change before the rule is finalized, this serves as a reminder to regularly evaluate your documentation, coding, and operational workflows. Efficient processes help practices remain compliant while supporting accurate reimbursement.
2: New MIPS Reporting Changes Are Being Proposed
The proposed rule includes updates to MIPS reporting, including the introduction of MIPS Core Measures and other refinements designed to streamline quality reporting across specialties. CMS proposes sunsetting traditional MIPS beginning with the 2029 performance period.
What this means: Clinicians would have until the end of 2028 to move to an MVP. If this proposal is made permanent, practices still reporting traditional MIPS should treat the next two years as a transition runway rather than waiting for the final deadline.
3: CMS Continues Its Transition Toward MVPs
CMS continues to move toward MIPS Value Pathways (MVPs) as the future of quality reporting. Under the proposed rule, traditional MIPS reporting would be phased out, with MVPs becoming the primary reporting framework in future performance years.
What this means: There's no immediate action required, but this proposal reinforces the importance of understanding how MVPs may affect your reporting strategy in the years ahead. Practices that stay informed now will be better prepared when future requirements take effect.
How Ezderm Helps Practices Stay Prepared
Regulatory requirements will continue to evolve, but preparation doesn't have to wait until the final rule is published.
Ezderm's integrated MIPS tools, Quality Reports, and documentation workflows help practices monitor performance throughout the year, making it easier to stay organized, identify potential gaps, and adapt to future reporting requirements with confidence.
Final Thoughts
The proposed 2027 Medicare Physician Fee Schedule provides an early look at where CMS may be headed, but it's important to remember that these changes are not yet final.
We'll continue monitoring the rulemaking process and share updates after CMS releases the final Physician Fee Schedule later this year. Until then, staying informed—and maintaining strong documentation and reporting practices—is the best way to prepare for what's ahead.
