ACG, AGA, and ASGE recently submitted joint recommendations to the Centers for Medicare & Medicaid Services (CMS) on two CY 2027 proposed rules: the Medicare Physician Fee Schedule (PFS) proposed rule and the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) proposed rule.

The societies urged CMS to account for rising practice costs and the clinical complexity of gastroenterology services by adopting evidence-based policies that support sustainable practices and preserve access to timely, high-quality care. The final Medicare rules are expected later this fall.

If finalized, the proposed policies would:

• Reduce payment across sites of service. Most gastroenterologists would be subject to the lower non-qualifying APM conversion factor because no GI-related Advanced Alternative Payment Models (APMs) gives a realistic opportunity to earn the higher qualifying APM update. That would cut physician payment for facility-based endoscopy by an average of 3%. In addition, ASC payments for most GI endoscopy procedures are expected to decline by approximately 8%.
  

• Increase administrative burden. Replacing the G2211 visit-complexity add-on code with new modifiers would require practices that currently use G2211 to update EHR systems, coding guidance, billing edits, staff education, and compliance processes. Proposed informational modifiers BB and BC could create administrative burden and potential liability if they are not reported appropriately.
  

• Limit meaningful, specialty-specific quality reporting for GI. Starting with the CY 2029 performance period, gastroenterologists not participating in an Advanced APM would be required to report through MIPS Value Pathways (MVPs), even though the Gastroenterology Care MVP still lacks enough measures to reflect the specialty's scope of practice. CMS also proposes removing measures Q320 (Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients) and NHCR4 (Repeat Screening or Surveillance Colonoscopy Recommended Within One Year Due to Inadequate Bowel Preparation) from the MIPS quality measure inventory, which would leave many gastroenterologists unable to report any colonoscopy-specific quality measure.

In our comment letters, we urged CMS to address proposed policies and work directly with the physician community on evidence-based approaches that protect access to high-quality GI care.

Resources

For more information, read the final comment letters and July summaries:

• 2027 Medicare Physician Fee Schedule Comment Letter

• 2027 OPPS/ASC Payment System Comment Letter

• 2027 Medicare Physician Fee Schedule Summary

• 2027 OPPS/ASC Payment System Summary