Medicare has announced the proposed 2027 Medicare Physician Fee Schedule and once again, pathology faces a reduction in payments. The temporary payment relief of 2.5% provided by the “One Big Beautiful Bill Act” expires at the end of 2026 and the proposed 2027 fee schedule will result in an estimated 2.4% payment reduction. The non-APM qualifying conversion factor for 2027 is proposed at $32.8409, which is a decrease of 1.7% from 2026.
Misvalued codes are a topic of special interest in the proposed rule, with a focus on CPT® 88305, a high-volume surgical pathology code. The Centers for Medicare and Medicaid Services (CMS) is seeking public comment regarding whether that code family is potentially misvalued after receiving a letter from the Maryland Health Care Commission (MHCC) questioning the current value of these services.
MSN is also closely watching proposed Relative Value Unit (RVU) changes and will provide a customized impact analysis for each practice once the Final Rule is announced. The College of American Pathologists (CAP) impact table compares the 2026 and 2027 proposed RVUs and payments by procedure code.
Quality Payment Program Proposed Changes
The 2027 Proposed Rule would formalize previously announced changes to the Medicare Quality Payment Program (QPP), including sunsetting traditional MIPS beginning with the 2029 performance period and transitioning to the MIPS Value Pathway (MVP) program. A MIPS Core Measures program would also begin in 2027, requiring every clinician to report at least one measure fundamental to their specialty. Reporting of the core measure would replace reporting of the current “high priority” measure.
MVPs for pathology include seven MIPS Clinical Quality Measures (CQMs), four of which are available through the MSN Quality Clinical Data Registry (QCDR) and include:
- QMM21 Incorporating results of concurrent studies into Final Reports for Bone Marrow Aspirate of patients with Leukemia, Myelodysplastic syndrome or Chronic Anemia
- QMM25 Structured Reporting for Urology Specimens – TPS
- QMM29 Use of Appropriate Classification System for Lymphoma Specimen
- QMM30 Appropriate Use of Bethesda System for Reporting Thyroid Cytopathology on Fine Needle Aspirations (FNA) of Thyroid Nodule(s) (formerly QMM22)
Reimbursement trends and the importance of your voice
While pathology professionals have dealt with declining reimbursement trends for more than a decade, a 2024 presentation by the College of American Pathologists (CAP) confirms the reality of our world, noting payments to pathologists have decreased by approximately 7% over the past six years while physician practice costs increased by nearly 17%. That trend continues in the proposed rule for 2027.
The American Medical Association (AMA) expanded on the financial impact of ever-declining Medicare fee schedules in a 2025 Medical Economics article that quoted a letter from AMA CEO John Whyte, MD, MPH to the Centers for Medicare and Medicaid Services (CMS) commenting on the proposed 2026 fee schedule. That letter noted, “Between 2001 and 2025, Medicare physician pay remained virtually flat even though the cost of running a medical practice increased 59 percent,” Whyte’s letter stated. “Adjusted for inflation in practice costs, Medicare physician pay declined 33 percent from 2001 to 2025.”
Pathology groups are urged to provide comments to Congress regarding how the proposed fee schedule and related changes will impact their practices.
Comments to CMS are due by September 14, 2026 with the following guidance provided in the Federal Register dated July 16, 2026.
When commenting, please refer to file code CMS-1848-P.
Comments, including mass comment submissions, must be submitted in one of the following three ways (please choose only one of the ways listed):
- Electronically. You may submit electronic comments online.
- By regular mail. You may mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016. Please allow sufficient time for mailed comments to be received before the close of the comment period.
- By express or overnight mail. You may send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
