CY 2027 Medicare PFS and OPPS proposed rules: key implications for wound care across facility and non-facility settings

Abstract

The Centers for Medicare & Medicaid Services (CMS) CY 2027 Medicare Physician Fee Schedule (PFS) proposed rule contains several provisions with direct implications for wound care delivery. The proposals include lower physician conversion factors, a new 50% payment reduction when separately identifiable office/outpatient evaluation and management (E/M) services are furnished on the same day as 0-, 10-, or 90-day global procedures, replacement of HCPCS G2211 with percentage-based modifiers, continued evolution of cellular, acellular, and matrix-like product (CAMP) payment, national valuation of real-time bacterial fluorescence wound imaging, practice-expense reform, and changes to remote physiologic and therapeutic monitoring. The same-day E/M proposal is especially important for wound clinicians because interventions such as sharp surgical debridement are commonly performed and medically necessary during wound care encounters. Importantly, as currently drafted, the proposal is limited to office/outpatient E/M services, which in wound care are commonly furnished in private physician offices and hospital outpatient departments (HOPDs). It does not currently extend to appropriately reported home/residence or nursing-facility E/M services, including those furnished in POS 12, 13, 31, and 32. CMS is seeking comment on whether the policy should later extend to other E/M categories. Facility and non-facility effects also differ because hospital outpatient departments receive separate facility reimbursement while independent office and mobile practices bear practice expense directly. This summary reviews the proposed policies most relevant to wound care and distinguishes their expected application across common sites of service.