CMS Proposes a Decrease to Anesthesia Payments in 2027; Makes Significant Changes to Anesthesiology MIPS Reporting

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS) proposed rule, which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). CMS proposed a reduction to the anesthesia conversion factor, increasing the financial strain anesthesia groups are facing. The proposed rule has a comment period that ends September 14, 2026. Final regulations will be issued on or around November 1 and unless otherwise noted, policies will be effective on January 1, 2027.

ASA is deeply disappointed by the proposed conversion factors as they come at a time when inflation and increased costs are affecting anesthesia groups. The proposed rule underscores that the Medicare payment system is fundamentally broken and that legislative reforms are needed. ASA remains committed to working with legislative stakeholders and regulatory agencies to reverse this negative impact on anesthesiologists and propose constructive and meaningful solutions. Such legislative reforms should include an annual adjustment for physicians to partially account for inflation and the modernization of fee schedule budget neutrality requirements. 

Fee Schedule Provisions:

CY 2026 marked the first year that the PFS conversion factor (CF) differs based on whether qualified clinicians are participating in an Advanced Alternative Payment Model (APM). MACRA provides for a 0.75% base payment update for items and services furnished by Qualifying APM Participants and a 0.25% base payment update for other items and services. Most anesthesiologists do not qualify for the higher base payment update. 

As a result, the proposed 2027 anesthesia CF is:  

• $20.4165 for items and services furnished by Qualifying APM Participants, representing a 0.8% decrease from the 2026 anesthesia CF of $20.5998.
• $20.2143 for other items and services, representing a 1.38% decrease from the 2026 anesthesia CF for those services of $20.4976.

The proposed 2027 RBRVS CF is:

• $33.1693 for items and services furnished by Qualifying APM Participants, which reflects a 1.19% decrease relative to the 2026 CF of $33.5675
• $32.8409 for other items and services, which reflects a 1.68 % decrease relative to the 2026 CF for those services of $33.4009.

The decreases in the conversion factors largely stem from the expiration of the 2.5% physician payment increase that was authorized for CY 2026 under the One Big Beautiful Bill Act (H.R. 1).

The change to the PFS CF incorporates several factors: 

• A statutory annual update of +0.75% for items and services furnished by Qualifying APM   Participants and an update of +0.25% for other items and services, as authorized under MACRA. Over time, the 0.5% discrepancy between these two conversion factors will grow resulting in a significant advantage of APM participants over all other services and arrangements.  
• A 0.53% budget neutrality adjustment, required by law, to offset decreases work Relative Value Units (RVUs) for some services proposed elsewhere in the fee schedule. This means spending in one year needs to be balanced by reductions and CMS cannot increase or decrease expenditures by more than $20 million without triggering automatic budget neutrality adjustments. While the budget neutrality adjustment is often negative, a positive budget neutrality adjustment signals that CMS is proposing policies elsewhere in the rule that will reduce overall work RVUs.
• A 0.30% Anesthesia Fee Schedule Practice Expense and Malpractice Adjustment. 

Specialty Impact on Anesthesia and Pain Medicine

Actual payment rates are impacted by a range of proposed policy changes related to physician work, practice expense, and malpractice RVUs. CMS estimated these changes in Table D-B5, in the proposed rule. Impact by practice will vary based on service mix. Specialty impacts ranged from -9% for Dermatology and Otolaryngology to +12% for Clinical Social Workers. The table indicates that the impact of policies in the proposed rule will have on anesthesiology and interventional pain management. 

Note, statutory across-the-board updates to the CF are not reflected in the impact table. The figures below are CMS estimates.

*Note: The 0.75 percent and 0.25 percent updates to the CY 2027 qualifying APM and nonqualifying APM conversion factors are statutory changes that take place outside of budget neutrality, and therefore, are not captured in the specialty impacts displayed in the table above.

Source: Table D-B5, CY 2027 PFS proposed rule, display copy

Telehealth Critical Care Consultations

CMS established 2 new G codes, G0508 (Telehealth consultation, critical care, initial, physicians typically spend 60 minutes communicating with the patient and providers via telehealth) and G0509 (Telehealth consultation, critical care, subsequent, physicians typically spend 50 minutes communicating with the patient and providers via telehealth) to report telehealth consultations for a patient requiring critical care services.

Anesthesia Add-on Codes

CMS is soliciting comments on three anesthesia services (01953, 01968, 01969) to confirm whether the concept of an add-on global period assignment would be appropriate for these anesthesia codes. The selected anesthesia codes are reported in addition to the primary procedure to report the additional dose or level. ASA will prepare a response to this solicitation.

Please contact [email protected] with any questions related to the Medicare Physician Fee Schedule.

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Quality Payment Program (QPP) Provisions:

CMS also released its 2027 QPP proposals. The proposed rule provides details on how CMS intends for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APMs), and other features of the QPP during the 2027 performance year.

During prior rulemaking, CMS finalized a policy to maintain the MIPS performance threshold at 75 points through the CY 2028 performance period. Clinicians scoring below 75 points during the 2027 performance year would receive a negative payment adjustment in the 2029 MIPS performance year. CMS will also maintain the 75% data-completeness threshold for the MIPS Quality performance category The weights of the four MIPS performance categories are established by law and remain unchanged for the 2027 performance year (Quality – 30%, Cost – 30%, Promoting Interoperability – 25%, Improvement Activities – 15%). 

For the 2027 reporting year, CMS proposes to:

• Remove QID 430: Prevention of Post-Operative Nausea and Vomiting – Combination Therapy from MIPS and the Anesthesiology Specialty Measure Set. CMS states that the measured quality action has become a “standard of care” and has limited opportunity to improve clinical outcomes. CMS reports an average performance rate of 99.34%, making the measure extremely topped out. 
• Remove QID 463: Prevention of Post-Operative Vomiting – Combination Therapy (Pediatrics) from MIPS and the Anesthesiology Specialty Measure Set for the same reason. CMS reports an average performance rate of 98.99%. 
• Add AQI48: Patient-Reported Experience with Anesthesia as a MIPS quality measure.
• Add ePreop31: Intraoperative Hypotension Among Non-Emergent Noncardiac Surgical Cases as a MIPS quality measure.

CMS proposes to annually publish a list of topped-out measures that may earn up to 10 points in circumstances when clinicians have limited alternatives within their applicable specialty measure set or MVP.

Anesthesiologists will continue to have the opportunity to report the Patient Safety and Support of Positive Experiences with Anesthesia MVP in 2027.

For the 2027 performance year, CMS proposes to remove two quality measures from the Anesthesiology MVP:

• QID 430: Prevention of Post-Operative Nausea and Vomiting – Combination Therapy 
• QID 463: Prevention of Post-Operative Vomiting – Combination Therapy (Pediatrics) 

CMS proposes to add four quality measures to the Anesthesiology MVP:

• Intraoperative Hypotension Among Non-Emergent Noncardiac Surgical Cases, proposed as a new MIPS quality measure and designated as an MVP core measure. 
• Patient-Reported Experience with Anesthesia, proposed as a new MIPS quality measure. 
• AQI65: Avoidance of Cerebral Hyperthermia for Procedures Involving Cardiopulmonary Bypass, a QCDR measure. 
• AQI71: Ambulatory Glucose Management, a QCDR measure. 

CMS proposes a core set of MVP measures for anesthesiologists to report:

• QID 404: Anesthesiology Smoking Abstinence 
• QID 477: Multimodal Pain Management 
• Intraoperative Hypotension Among Non-Emergent Noncardiac Surgical Cases 

CMS proposed no additions or removals to the list of nine (9) Improvement Activities included in the Anesthesiology MVP.

Future Mandatory MVP Reporting

In recent years, CMS signaled its intent to phase out Traditional MIPS but had not formally proposed a timeline. In this rule, CMS proposes to eliminate “Traditional MIPS” beginning with the 2029 performance period and 2031 payment year. Beginning in 2029, MIPS-eligible clinicians who do not participate through an APM Performance Pathway would be required to report through an MVP. Traditional MIPS would remain available through the 2028 performance period.

Ambulatory Specialty Model

CMS largely maintains the existing Ambulatory Specialty Model (ASM) framework while proposing several program updates. The model will run from 2027 to 2031 and targets anesthesiologists and other specialists who frequently treat low back pain or heart failure in selected geographic areas. Notable quality measure changes include replacing Functional Status Change for Patients with Low Back Impairment (MIPS 220) with Functional Outcome Assessment (MIPS 182) and adding an MRI Lumbar Spine for Low Back Pain measure (modified for ASM). Other notable changes include a rural scoring adjustment, voluntary patient-reported outcome-based performance measures (PRO-PM), and a phased implementation of an Electronic Prior Authorization measure through the Promoting Interoperability category.  Eligible ASM physicians, including anesthesiologists and pain management providers, will be assessed individually and subject to performance-based payment adjustments ranging from -9% to +9% in the first year.

Requests for Information

CMS also issued several requests for information that could shape future QPP policies. These include requests for feedback on scoring under mandatory MVP reporting, the transition to FHIR-based digital quality measurement, future performance-based electronic prior-authorization measures and the methodology used to assign publicly reported star ratings to administrative claims measures. CMS also seeks input on specialty participation in the Medicare Shared Savings Program and the use of electronic prior authorization by ACOs.

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].

For more information:

• Proposed Rule text
• CMS Press Release
• Medicare Physician Fee Schedule Fact Sheet
• Quality Payment Program Fact Sheet
• Medicare Shared Savings Program Fact Sheet