Gastroenterologists would see lower Medicare payment across nearly every site of service in 2027 under proposed rules from the Centers for Medicare & Medicaid Services, with the deepest physician cuts landing on office-based endoscopy and the steepest facility cuts on upper GI procedures performed in ambulatory surgery centers.
CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, following the CY 2027 Hospital Outpatient Prospective Payment System and ASC proposed rule on July 2. The comment period closes Sept. 14, with final rules expected in the fall.
Most of the payment movement is familiar — an expiring congressional increase, another year of practice expense revisions. The genuinely new item is a policy CMS proposed and abandoned in 2019 and has now revived: paying additional same-day services at 50% when an E/M visit and a procedure are reported together. It would reach a small share of endoscopy claims, but cut deeply into the ones it touches.
Conversion factors fall as a temporary increase expires
Beginning in 2026, statute requires CMS to maintain two conversion factors, one for qualifying participants in advanced alternative payment models and one for everyone else. For 2027, CMS proposes $33.17 for qualifying APM participants, a decrease of $0.40, or 1.19%, and $32.84 for non-qualifying practitioners, a decrease of $0.56, or 1.68%.
The math is less about a new cut than an expiring one. Statutory updates add 0.75% for qualifying APM participants and 0.25% for everyone else, and CMS applies an estimated 0.53% adjustment for proposed work RVU changes. Offsetting those is the expiration of the one-year 2.5% conversion factor increase Congress enacted for 2026 under Public Law 119-21.
Where the cuts land in GI
Physician payment reductions are larger in the office than in the facility setting, according to AGA, which estimates an average 5% decline for office-based endoscopy against an average 3% decline for endoscopy in ASCs and hospital outpatient departments, where most endoscopy is performed. GI testing services follow the same pattern, with office-based testing down roughly 5% and facility-based testing down roughly 3%. The American College of Gastroenterology puts the facility figure at about 3% as well.
Those reductions land on top of last year’s. In 2026, CMS applied a 2.5% efficiency adjustment to the work RVUs of non-time-based codes and revised its practice expense methodology in a way that raised physician payment for office-based procedures while cutting it in ASC and HOPD settings, an effort to steer care toward lower-cost sites. AGA put the combined 2026 effect at an average 8% cut for facility-based GI endoscopy and an average 16% increase for office-based endoscopy — though it notes most GI practices could not restructure quickly enough to capture that office-side gain. The 2027 proposal would erode part of it for practices that did.
Facility payment is a separate stream, and it moves differently. Under the OPPS and ASC proposed rule, ASCs and hospital outpatient departments meeting quality reporting requirements would receive an overall 2.4% facility payment increase. GI does not share evenly in it. AGA attributes proposed changes to the ASC weight scalar, a budget-neutrality adjustment factor, for an approximately 8% decline in ASC payment for most upper GI endoscopies and a 3% decline for lower GI endoscopies, while payment for GI endoscopy stent placement codes would rise 16%. ACG estimates the aggregate ASC decline for many GI procedures at about 2%.
Practice expense drives the cuts; work values hold steady
For the second consecutive year, CMS proposes revising its indirect practice expense calculations, though by a different route than in 2026. The agency would phase out the step anchoring specialty-level PE RVUs to practice expense per hour data from 2007 or earlier, replacing it with a stabilizer meant to limit year-to-year volatility.
CMS also proposes capping annual increases or decreases in a code’s PE RVU at 5%. As AGA points out, the cap slows the pace of change without limiting its eventual magnitude: codes whose values under the new methodology differ by more than 5% would keep adjusting incrementally in later years, including after the two-year phaseout of the Indirect Practice Cost Index concludes in CY 2028. The PE RVUs shown for 2027 may not reflect where a code ultimately lands.
Work RVUs, by contrast, are generally unchanged, which is a meaningful shift from 2026’s efficiency adjustment that CMS justified on the reasoning that physicians grow more efficient over time. Because the agency may apply that adjustment every three years, AGA notes the next application could come as early as 2029.
G2211 would become a modifier
CMS proposes replacing HCPCS code G2211, the visit complexity add-on used in GI for ongoing care of conditions such as advanced liver disease, Crohn’s disease, and ulcerative colitis, with a two-digit modifier appended to the base E/M code. The placeholder modifier, MOD1, would increase payment for the associated E/M code by 16%, applying the same percentage across all visit levels rather than the current flat rate.
The swap from a flat amount to a percentage makes the effect uneven. AGA’s analysis finds that lower-level visits reported with MOD1 would be paid less than they are today with G2211, while some higher-level visits would be paid marginally more. A second modifier, MOD2, would add 32% but be limited to practitioners in qualifying accountable care organizations, including Shared Savings Program and Long-term Enhanced ACO Design model participants, a group that would exclude most gastroenterologists.
The operational lift may matter more than the dollars. Practices currently reporting G2211 would need EHR updates, coding education, modifier logic, billing edits, and compliance review.
Same-day E/M reductions: narrow but sharp
CMS proposes reducing payment when a separately identifiable office or outpatient E/M visit is furnished on the same day as a procedure with a 0-, 10-, or 90-day global period by the same physician or a physician in the same practice. The highest-paid service would be paid in full and every other same-day service at 50%. The agency argues that efficiencies exist when the same physician provides an E/M service alongside a global-period procedure and that current methodology likely pays twice for the same work.
ACG warns that gastroenterologists who frequently bill an E/M visit with a procedure could see lower reimbursement. AGA’s read is that the aggregate revenue effect on endoscopy should be limited, because Medicare data show same-day E/M billing is uncommon, ranging from roughly 0.3% to 0.7% of claims depending on the code. Where the policy does apply, the per-claim hit is substantial: AGA calculates a combined RVU reduction of approximately 16% to 25% for EGD with biopsy (CPT code 43239) reported with higher-level new and established patient E/M codes, and approximately 10% to 21% for colonoscopy with snare polypectomy (CPT code 45385).
Remote monitoring rules tighten
CMS proposes limiting remote therapeutic monitoring to established patients, requiring a separately reportable initiating visit before remote physiologic or therapeutic monitoring begins, and paying for these services only when they are furnished by clinical staff employed by the practice rather than by contractors. The agency is also seeking comment on bundling the RPM and RTM code families into four new HCPCS G codes, citing recent Office of Inspector General findings it says cannot be resolved within the current coding structure.
AGA identifies the contractor restriction as the most operationally significant of the three, since it would reach arrangements that rely on outside vendors for monitoring infrastructure, patient outreach, or clinical staffing. Practices using vendor-supported remote monitoring for chronic GI conditions would need to assess whether those models remain compliant.
New ESD values, fewer GI quality measures
Not everything in the rule cuts against GI. CMS proposes physician work RVUs of 15.00 for upper GI endoscopic submucosal dissection and 16.38 for lower GI ESD, which would make them the highest-valued work in GI endoscopy when the codes take effect in 2027.
CMS also proposes removing two quality measures with direct GI relevance: appropriate follow-up interval for normal colonoscopy in average-risk patients, and repeat screening or surveillance colonoscopy recommended within one year because of inadequate bowel preparation. Separately, MIPS Value Pathways would become mandatory beginning with the CY 2029 performance period for gastroenterologists not participating in an advanced APM. ACG argues the combination narrows the set of measures most applicable to practicing gastroenterologists.
What’s next
Comments are due to CMS by Sept. 14. ACG, AGA, and the American Society for Gastrointestinal Endoscopy have circulated a joint preliminary summary of the proposals to members and typically file a combined comment letter, as they did on the 2026 rules. Because the policies remain proposed, both societies advise practices to wait for the final rules before making significant operational or financial decisions.