CMS released its calendar year 2027 Physician Fee Schedule (PFS) proposed rule on July 14, kicking off a 60-day public comment window that closes September 12, 2026. The rule governs Medicare payment rates for physicians, nurse practitioners, physician assistants, certified registered nurse anesthetists, and certified nurse midwives — and for the roughly 355,000 NPs who bill Medicare independently, the fine print matters. The final rule will be published in November and takes effect January 1, 2027.
The 85% Rate: Still There, Still Contested
The most consequential number for NPs in the fee schedule is not a new one: the 85% reimbursement rate for services independently billed by nurse practitioners, compared with the physician rate for identical services. This differential has been embedded in statute since the Balanced Budget Act of 1997 and requires congressional action to change — CMS cannot eliminate it through the rulemaking process alone. The 2027 proposed rule does not propose to alter the 85% statutory rate.
For context: when an NP bills a new patient office visit (CPT 99205) independently, Medicare reimburses at 85% of what a physician would receive for the same code. In states with full practice authority — the 26 states where NPs can practice without physician oversight agreements — this billing differential persists even though the NP is providing care under the same legal framework as a physician. The gap translates to roughly $8–$22 less per office visit depending on the code, which compounds significantly at practice scale.
AANP, the American Nurses Association, and a coalition of APRN organizations have advocated for payment parity legislation in Congress — the Improving Seniors' Timely Access to Care Act has addressed some elements — but the statutory 85% rate for independent NP billing remains in place for 2027.
Telehealth Extensions: A Win for NP Practices
One of the more NP-relevant provisions in the 2027 proposed rule is the continuation of telehealth flexibilities that have been extended repeatedly since the COVID-19 public health emergency. CMS is proposing to make several key telehealth policies permanent rather than allowing them to lapse:
- Audio-only telehealth for established patients. CMS proposes to permanently allow audio-only (telephone) services to count as telehealth visits for established patients who cannot access video platforms — a provision that disproportionately benefits NPs in rural and underserved communities who serve elderly patients without reliable broadband access.
- Originating site flexibility. Patients can continue to receive Medicare telehealth services from their homes rather than requiring a qualifying clinical site as the originating location — eliminating a pre-pandemic requirement that had severely restricted telehealth uptake.
- Mental health telehealth with in-person requirement waiver. CMS proposes a modified mental health telehealth policy that reduces but does not eliminate the in-person requirement added in prior rulemaking — psychiatric NPs and APRNs providing mental health telehealth services will want to review this provision carefully.
The permanent telehealth provisions are broadly positive for NP practices, particularly in primary care and behavioral health, where telehealth has become embedded in patient care workflows over the past several years.
Behavioral Health: New Add-On Codes
The 2027 proposed rule continues CMS's expansion of behavioral health payment through a set of proposed new add-on codes for care coordination and collaborative care model services. For psychiatric mental health NPs and primary care NPs managing behavioral health conditions, these codes represent additional billable work that is currently being delivered but not captured in existing E/M visits:
- Proposed new add-on code for complex psychiatric medication management coordination — relevant to PMHNPs managing patients on multiple psychotropic agents
- Expanded billing opportunities under the Collaborative Care Model (CoCM), which allows primary care practices — including NP-led practices in full practice authority states — to bill for integrated behavioral health coordination
- New code proposals for care management services targeting patients with serious mental illness who have been recently discharged from inpatient psychiatric settings
The telehealth permanence proposal is the headliner for most NP practices. But the behavioral health add-on codes are worth studying closely, particularly for psychiatric NPs and primary care NPs who've been coordinating care that Medicare wasn't paying for. These codes don't create new clinical work — they create payment pathways for work that's already happening. If the proposed codes survive the final rule intact, practices should be updating their billing protocols before January 1.
Conversion Factor and RVU Changes
Every year, the PFS adjusts the conversion factor — the dollar value applied to each relative value unit — which determines the actual dollar payment for every procedure code. The 2027 proposed rule includes a modest conversion factor adjustment that reflects statutory budget neutrality requirements. Because the PFS is budget-neutral by law, increases in RVUs for some services must be offset by reductions elsewhere or by lowering the conversion factor. NPs billing primarily E/M codes (office visits, preventive visits) will see relatively modest net payment changes in 2027; NPs billing surgical assists or procedural codes may see more significant shifts depending on how specific RVU recalibrations shake out in the final rule.
The full proposed conversion factor and specialty-specific impact tables are available in the Federal Register notice. Practices should run their top 20 CPT codes through the proposed 2027 rates to estimate net payment impact before the comment period closes — if the proposed rates create problematic payment reductions for services central to your patient population, the comment period is the formal mechanism for flagging those concerns.
How to Comment
CMS takes public comments on the proposed rule seriously — the PFS final rule published each November frequently reflects adjustments made in response to organized clinician commentary. NPs and APRNs can submit individual comments, but the most effective channel is through professional associations: AANP, AANA for CRNAs, ACNM for certified nurse midwives, and NACNS for clinical nurse specialists typically submit detailed, data-backed comment letters on members' behalf. Submitting your own comment through regulations.gov using docket number CMS-1807-P before September 12 puts your perspective on the record directly, independent of association submissions.