2027 Medicare Fee Schedule: How Optometrists Should Prepare

Medicare’s 2027 physician fee schedule is still a proposal, but its direction is clear. On 14 July 2026, CMS released the proposed rule for calendar year 2027 (CMS-1848-P). It would lower the main conversion factor by 1.68%, trim most eye exam codes by 3% to 5% nationally, and halve payment for the lower-paid service when an office visit and a minor procedure are billed on the same day. The comment period closed on 14 September. The final rule is not out yet, and the numbers can still change. This guide sets out what the proposal says, what it would do to the codes an optometry practice bills most, and what to get ready before 1 January 2027.

What CMS Has Proposed for 2027

Medicare pays for each service by multiplying its relative value units (RVUs) by a dollar amount called the conversion factor. Since 2026 there have been two conversion factors: one for qualifying participants in advanced alternative payment models (APMs), and one for everyone else. Most independent optometry practices are paid at the non-qualifying rate.

The figures come from Tables D-B1 and D-B2 of the proposed rule as published in the Federal Register (document 2026-14327), and match the CMS fact sheet, which rounds them to $32.84 and $33.17.

Why the Conversion Factor Is Falling

The cut is mostly the end of a one-year boost. Public Law 119-21 added 2.5% to the 2026 conversion factors for services furnished in 2026 only. CMS builds the 2027 figure by removing that 2.5%, then applying two increases:

• A statutory update of 0.25% for non-qualifying clinicians and 0.75% for qualifying APM participants.
• A budget neutrality adjustment of +0.53%, which offsets the proposed changes to work RVUs across the whole fee schedule.

The two increases do not make up for the lost 2.5%, so the net result is a smaller conversion factor. For a practice, this part of the cut applies evenly to every code.

What the Proposal Does to Common Optometry Codes

RVUs change too, and for eye care they mostly fall. In its specialty impact table (Table D-B5), CMS estimates that RVU changes alone would lower optometry’s total Medicare allowed charges by about 2%, almost all of it from practice expense. Ophthalmology is estimated at about −3%. These estimates do not include the conversion factor change, so the two effects add up.

The table below multiplies each code’s total non-facility RVUs by the conversion factor, using the CY 2026 final rule addenda and the CY 2027 proposed rule Addendum B. These are national amounts before your locality’s geographic adjustment, at the non-qualifying rate, and the 2027 column is proposed, not final.

Two practice expense proposals drive most of the RVU movement. CMS would drop the indirect practice cost index, which rests on old survey data, from the practice expense formula. To limit the swings that would cause, it would cap any code’s yearly practice expense change at 5% up or down. The rule does not add a new efficiency adjustment for 2027; CMS applied a 2.5% cut to work RVUs in 2026 and plans to repeat that review every three years.

Averages hide spread. CMS’s practitioner-level impact file shows about 40% of optometrists losing 1% or more of their total RVUs, and about 23% gaining 1% or more. Your result depends on your code mix, which is why the first job below is to model your own claims. Our optometry CPT and ICD-10 reference guide covers when each exam code applies.

One smaller change affects practices that bill office visit codes for ongoing care. CMS proposes turning add-on code G2211 into a modifier on the visit code that adds 16% to that visit’s payment, instead of a separate flat amount.

The Same-Day Visit and Procedure Proposal

This is the proposal most likely to change how an optometry claim is built. Today, when you remove a corneal foreign body and also perform a significant, separately identifiable office visit, you bill both, with modifier 25 on the visit. Medicare pays each in full.

Under the proposal, when the same physician, or a physician in the same group, furnishes an office or outpatient E/M visit on the same day as a procedure with a 0-, 10- or 90-day global period, the most expensive service is paid at 100% and every other procedure or visit that day at 50%. CMS asked for comments on whether 25% would be a better reduction, so the percentage itself is open.

A worked example, at proposed national rates. A patient with a corneal foreign body sees you for a 99213 visit with modifier 25, and you perform 65222, which has a 0-day global period.

• 99213 is the higher-paid service, so it is paid in full: $93.27.
• 65222 drops from $64.04 to $32.02.
• The pair would pay $125.29, against $161.99 under the 2026 rates, a fall of about 23%.

Two limits matter. First, the rule text names office and outpatient E/M visits, the 99202 to 99215 family. It does not say whether the 92000-series eye exam codes are included, so a 92012 billed with 65222 may or may not be caught; watch the final rule for that detail. Second, CMS says plainly that it does not consider it appropriate to move a visit to another day to avoid the cut, and that it can monitor billing patterns for this. Do not change scheduling to protect revenue.

CMS also asked how the policy should apply to an exam on the same day as an intravitreal injection. That question mainly concerns retina practices, but it shows the agency is looking closely at eye-care same-day billing. For the modifier rules that apply today, see our guide to reducing optometry claim denials.

MIPS and MVP Changes for Eye Care

The quality program changes are slower but worth planning for now:

• MIPS core measures from 2027. Starting with the 2027 performance period, CMS proposes that clinicians report at least one designated core measure, replacing the current rule of one outcome or high-priority measure. Small practices would be exempt from this requirement.
• Traditional MIPS ends in 2029. CMS proposes that MIPS Value Pathways (MVPs) become the only MIPS reporting option from the 2029 performance period, which sets 2031 payments. Traditional MIPS stays available until then.
• An MVP that covers optometry already exists. CMS says the Complete Ophthalmologic Care MVP is most applicable to ophthalmology and optometry, and proposes changes to its measures for 2027.
• The performance threshold stays at 75 points. The proposal makes no change to it.

The proposal’s telehealth changes concern rural health clinics, federally qualified health centers and new codes outside routine eye care. None is specific to eye exams.

What to Do Before 1 January 2027

1. Model your own impact. Pull 12 months of Medicare claims, list your 15 most-billed codes by volume, and price them at the 2026 rate and the proposed 2027 rate for your locality. That single sheet tells you more than any national average.
2. Audit your modifier 25 pairs. Count how often you bill an office visit with a 0- or 10-day procedure such as 65222 or 67820 on the same day. Check that the documentation supports a separately identifiable visit, and estimate the revenue at 50%.
3. Decide on your MIPS route. If you report traditional MIPS, read the Complete Ophthalmologic Care MVP now and plan a practice year on it before it becomes mandatory.
4. Review payer contracts tied to Medicare. If a commercial contract pays a percentage of the Medicare fee schedule, check which year’s schedule it uses and when it updates. A falling Medicare rate can carry straight into those payments.
5. Plan the fee schedule update in your systems. Ask your EHR or billing vendor when the 2027 rates will load and whether the claim scrubber will apply the same-day reduction to expected payments. Otherwise every affected claim will look underpaid. Our guide to optometry revenue cycle management covers how expected-payment flags fit into posting.
6. Keep the medical and vision split clean. The cut applies to Medicare medical claims, not to vision plans. Billing medical eye care to the right payer matters more when each medical code pays less; our medical vs vision billing guide explains the split.

When the Final Rule Arrives

CMS usually publishes the final physician fee schedule rule in early November. When it does, check three things: the final conversion factors, whether the same-day reduction survived and at what percentage, and whether it reaches the 92000-series exam codes. Then rerun your model with the final numbers. We will update this guide when the final rule is published.

Our recommendation: plan for a cut of 2% to 5% on your Medicare exam and imaging codes, and treat the same-day reduction as likely but not settled. If your practice removes foreign bodies or performs other minor procedures alongside office visits, that is where your 2027 exposure is largest. Next, read our revenue cycle guide to make sure underpayments get caught once the new rates take effect.

Sources

• CMS: Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule fact sheet (14 July 2026)
• CMS: CMS-1848-P regulation page, addenda and specialty impact files
• Federal Register: CY 2027 PFS proposed rule, document 2026-14327 (16 July 2026)
• CMS: CMS-1832-F, CY 2026 PFS final rule and addenda