CY2027 MPFS: Radiology Pay Cut Framework
CMS proposed a 1.68% conversion factor cut on July 14 that hides a more dangerous story.
The headline number is $32.84. That is the proposed 2027 Medicare conversion factor for physicians not participating in an alternative payment model. It is down from $33.40 in 2026 - a $0.56 reduction, or -1.68%.
One point six eight percent. Written on paper, it sounds like a rounding error.
It is not a rounding error. It is the sixth consecutive year of effective physician payment erosion under Medicare.
The comment window closes September 14, 2026. That is six weeks away.
1. What Is Actually in the CY2027 Proposed Rule
On July 14, 2026, CMS released a 1,592-page proposed rule for the Medicare Physician Fee Schedule.
Provision 1: Two-Tier Conversion Factor
The proposed 2027 non-QPM conversion factor is $32.8409, down 1.68%.
Provision 2: Modifier 25 Same-Day Payment Cut
CMS proposes cutting E/M visits billed same-day as procedures to 50% if not the highest-valued service.
Provision 3: G2211 Deletion
Replaced by 16%/32% modifier for non-ACO/ACO practices.
Provision 4: Practice Expense Methodology
Work RVU plus clinical labor RVU for indirect expense allocation.
2. The Aggregate Hides the Code-Level Story
CMS estimates +2% for diagnostic radiology, +3% for IR. But CT angiography chest is +149% while upper extremity CT is -15%.
3. Twenty-Five Years of Compounding
Medicare physician payment has declined 33% in inflation-adjusted terms since 2001.
4. The Modifier 25 Proposal
IR groups billing $800 procedure plus $150 E/M: procedure stays at $800, E/M drops to $75.
5. MIPS Value Pathways
Traditional MIPS sunsets 2029. Radiology MVPs are the future performance program.
6. The Comment Window
Modifier 25 is a CMS policy choice, not statutory. Comments with data can change the final rule. Deadline: September 14, 2026.
Financial Modeling
Scenario A: Non-APM Diagnostic Radiology
Annual impact: -$43,200.
Scenario B: APM Practice
Annual impact: -$36,000.
Scenario C: IR with High Mod-25 Volume
Annual impact: over -$403,000.
What This Means For You
FQHC executives: Radiology access is downstream from radiology economics. Consolidation accelerates under these cuts.
Health systems: Model employed radiology financial position before October final rule.
Radiologists: Review ACR impact tables for your top CPT codes before September 14.
Investors: APM participation platforms and MVP reporting tools are positioned ahead of 2029 MIPS sunset.
Policy advocates: H.R. 6160 and H.R. 9693 need floor action before November.
Closing
The comment window is six weeks long. It closes September 14, 2026.
Jonathan Govette is the Co-Founder and CEO of Oatmeal Health, an AI lung cancer diagnostic company. Subscribe at oatmealhealthjonathangovette.substack.com