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ACR Urges CMS Transparency in 2027 Physician Fee Rule

Sept. 17, 2026

ACR® submitted comments to CMS about the 2027 Medicare Physician Fee Schedule (MPFS) proposed rule Sept. 11. In response to CMS’s proposed changes to its practice expense methodology, ACR requested greater transparency and analysis of the impacts of each proposed change individually and at the Current Procedural Terminology® (CPT®) code level to ensure that there are no unintended consequences of the multiple procedural changes.

Specifically, ACR noted that a CPT code for diagnostic digital breast tomosynthesis reflects a practice expense (PE) relative value unit of zero, which the College strongly believes is an error. ACR requested clarification regarding this issue and an analysis by CMS to ensure the application of practice expense methodology changes is correct.

Throughout its comments, ACR urges CMS to collaborate with physicians and specialty societies to ensure fair, stable payments. The College provided input on multiple other CMS proposals, including: 

  • Updates to prices for existing direct PE inputs
  • Updates to PE methodology – site of service payment differential
  • Efficiency adjustment
  • Procedures subject to the Multiple Procedure Payment Reduction (MPPR) and the Outpatient Prospective Payment System (OPPS) caps 
  • Accounting for Evaluation and Management resource overlap between stand-alone visits and global periods 
  • High-cost disposable supplies
  • Valuation of specific codes for 2027
  • Potentially misvalued services under the MPFS
  • CPT request for information (RFI)
  • RFI regarding duplicate laboratory testing, imaging, and result sharing and interoperability
  • Changes to primary care and care management due to technology and clinical artificial intelligence
  • Merit-based Incentive Payment System (MIPS) value pathways (MVPs)
  • MVPs scoring methodology RFI
  • Proposals directly applicable to third-party intermediaries (e.g., qualified clinical data registries and qualified registries) 
  • Fast Healthcare Interoperability Resources®-based digital quality measurement in the Quality Payment Program and other CMS quality programs - RFI
  • MIPS quality performance category

The College continues to work with CMS on radiology and radiation oncology issues and will keep members informed as the rulemaking process advances toward publication of the MPFS final rule in late fall.

For more information, contact Kathryn Keysor, ACR Vice President of Economic Policy.

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