CMS CY 2027 Proposed Rule: What ENT, Audiology and Speech Pathology Practices Need to Know

Comments close September 14, 2026, at 11:59 PM ET.

CMS released the CY 2027 Medicare Physician Fee Schedule Proposed Rule on July 14, 2026. Several provisions would meaningfully change how ENT, audiology and speech-language pathology practices are paid.

A few stand out. CMS is proposing to cut payment by 50% for additional same-day E/M services and procedures. It is proposing to rebuild the practice expense methodology. And it is proposing new coding for speech-language pathology that specialty societies did not ask for and are actively contesting.

The public comment period closes September 14, 2026, at 11:59 PM ET. After that date, CMS will not accept further comments. If these provisions are finalized as written, they could affect reimbursement, practice operations and patient access to care.

Below is a section-by-section summary of what we are watching, along with the links you need to submit a comment of your own.

Here’s what’s included:

1. Conversion factors are proposed to decrease again
2. The same-day E/M and procedure payment cut is the biggest ENT concern
3. G2211 would become a modifier
4. Practice expense methodology changes could shift reimbursement
5. Audiology and speech pathology services face added pressure
6. New speech-language pathology and vestibular codes for 2027
7. MPPR would apply to the new SLP treatment services
8. The proposed pediatric speech-language pathology G code (GSLPP)
9. Potential downstream Medicaid and managed care impact
   1. MIPS and quality reporting changes continueKey dates and the comment period
   1. How to comment and where to find more

1. Medicare Physician Fee Schedule Conversion Factors Are Proposed to Decrease Again

CMS is proposing separate conversion factors for 2027:

• APM Qualifying Participants (QPs): $33.17 (approximately -1.19%)
• Non-QPs/MIPS Clinicians: $32.84 (approximately -1.68%)

The decrease is driven primarily by the expiration of the temporary 2.5% physician payment increase Congress provided for CY 2026. Without new Congressional action, physician reimbursement will decline despite the statutory update and budget neutrality adjustment.

ENT Impact

• Lower reimbursement across office visits, procedures, and surgical services.
• Practices already facing staffing and supply cost increases may experience additional financial pressure.
• Actual impact will vary by procedure mix and RVU changes.

2. Proposed Same-Day E/M and Procedure Payment Reduction Is the Biggest ENT Concern

CMS is proposing a policy that would pay:

• The highest-valued service at 100%.
• Additional separately reportable E/M services and procedures with a 0-, 10-, or 90-day global period performed on the same day by the same physician or group practice at 50% of the normal payment amount.

Why This Matters for ENT

This could significantly affect common ENT workflows where an office visit is performed with an in-office procedure, such as:

• Flexible laryngoscopy
• Nasal endoscopy
• Cerumen removal
• Debridements
• Control of epistaxis
• Biopsies

Many ENT encounters involve a medically necessary E/M service and a procedure on the same date. Under this proposal, payment for one of those services could be substantially reduced. Specialty societies have raised significant concerns because same-day E/M and procedure reporting is common in ENT practices. This could also have implications for patient access to care.

3. G2211 Would Become a Modifier

CMS is proposing to convert G2211 from a separately billed HCPCS add-on code into a modifier-based reporting mechanism. Beginning January 1, 2027, CMS proposes replacing standalone add-on code G2211 with a dynamic, percentage-based modifier framework tied directly to the base office/outpatient E/M service.

ENT Impact

• Practices currently reporting G2211 may need workflow and EMR updates.
• The proposal changes both the reporting mechanism and the payment methodology.
• MOD1 (Standard Longitudinal Care Modifier): Provides a 16% payment increase above the base E/M code for general practices and specialists serving as the patient’s ongoing focal point of care.
• MOD2 (ACO Longitudinal Care Modifier): Provides a 32% payment increase above the base E/M code for practices participating in qualifying ACO models (e.g., MSSP or LEAD models).
• Interaction with Modifier 25: If an E/M visit with MOD1 or MOD2 is performed on the same day as a 0-, 10-, or 90-day global procedure subject to the proposed 50% Modifier 25 cut, the 16% or 32% premium would apply only to the reduced 50% payment amount, potentially compounding revenue loss.
• Practices should monitor final eligibility, documentation, reporting, and payment requirements carefully.

4. Practice Expense (PE) Methodology Changes Could Significantly Shift Reimbursement

The AAO-HNS has identified CMS’s proposed Practice Expense (PE) methodology revisions as one of the most significant issues in the CY 2027 Proposed Rule.

CMS is proposing several major changes to how indirect practice expense RVUs are calculated, including:

• Phasing out the Indirect Practice Cost Index (IPCI)
• Applying only 50% of the IPCI adjustment in 2027
• Eliminating the IPCI entirely beginning in 2028
• Revising how indirect practice expense is allocated among services
• Using more code-specific inputs, including:
  • Physician work
  • Clinical labor
  • Equipment costs
  • Supply costs
• Implementing policies intended to generally limit annual PE impacts to approximately ±5% per year for affected services.

Potential ENT Impact

• Services with substantial indirect practice expense allocations could experience payment changes.
• The impact may vary considerably by procedure depending on the relative weighting of physician work, labor, equipment, and supplies.
• Some services may see payment increases, while others may experience reductions as the methodology shifts toward code-level cost inputs.
• The effects of these changes could continue for several years as CMS completes the transition away from the IPCI methodology.

5. Audiology & Speech Pathology Services Face Additional Pressure

Audiology organizations are projecting an overall Medicare reimbursement reduction of approximately 3% for 2027. CMS estimates that overall audiology payment would decrease by 3%, largely due to proposed reductions in practice expense RVUs. Industry groups have also raised concerns that CMS assigned work RVUs below RUC recommendations for some new vestibular testing services.

CMS has also proposed reducing the 2027 conversion factor by 1.68% for most audiologists and speech-language pathologists who do not participate in a qualifying Alternative Payment Model (APM), in addition to proposed practice expense methodology changes that could reduce payment for many existing services. Because speech-language pathology is grouped with physical and occupational therapy for CMS’s specialty-level impact analysis, CMS does not provide a separate estimate for SLP services; however, ASHA states that SLPs should anticipate a reduction.

Potential Impact

• Lower reimbursement for diagnostic audiology and speech pathology services.
• Particular concern regarding valuation of some new vestibular services.
• Additional financial pressure on practices with significant audiology or speech pathology revenue.

For integrated ENT-audiology and/or speech pathology groups, these reductions could compound the physician payment cuts.

6. New Speech-Language Pathology and Vestibular Codes for 2027

CMS is proposing implementation of:

• 10 new Speech-Language Pathology treatment CPT codes
• 4 new vestibular diagnostic CPT codes

CMS accepted nearly all of the AMA RUC recommendations for these new services. However, CMS is proposing a lower work value for one vestibular testing add-on code, which could reduce reimbursement for that service.

Additional Concern: Multiple Procedure Payment Reduction (MPPR)

CMS is proposing that the new SLP treatment services be subject to the Multiple Procedure Payment Reduction (MPPR) policy.

ASHA is actively advocating against this proposal, citing concerns that the MPPR policy may not appropriately reflect the clinical work involved in speech-language pathology treatment.

ENT/Audiology/SLP Impact

• Audiology practices should prepare for implementation of the new vestibular code set.
• Speech pathology practices should prepare for implementation of the new SLP codes.
• Reimbursement for some vestibular services may differ from RUC recommendations.
• Practices employing speech-language pathologists should monitor final coding and payment guidance carefully.
• Application of MPPR to SLP services could significantly affect reimbursement for therapy services.

7. Proposed Pediatric Speech-Language Pathology G Code (GSLPP)

A major surprise in the proposed rule is CMS’s creation of GSLPP, a Medicare-specific HCPCS code for pediatric speech-language pathology treatment. CMS developed GSLPP outside the AMA CPT and RUC valuation process. CMS also proposes sunsetting CPT 92507 effective January 1, 2027, while implementing the new family of timed SLP treatment codes.

CMS proposes that GSLPP would:

• Be used for pediatric speech-language pathology treatment.
• Be valued using the work and practice expense assumptions historically associated with CPT 92507.
• Carry a work RVU of 1.30 based on 60 minutes of personally performed treatment.
• Be reportable only once per patient per day.
• Be designated as an “always therapy” service.
• Be subject to MPPR reductions.

Although GSLPP would be an untimed code, CMS’s proposed valuation assumes approximately 60 minutes of treatment.

Why ASHA Is Opposing GSLPP

ASHA has expressed significant concerns and is actively contesting the proposal.

ASHA believes pediatric speech-language pathology services are already represented within the new CPT code family, which differentiates treatment based on both clinical focus and duration. As a result, ASHA has raised concerns that GSLPP could:

• Undervalue lengthy or complex pediatric treatment sessions.
• Rely on outdated practice expense inputs.
• Create confusion due to inconsistent age limits in the proposal (CMS references both age ranges up to 18 and up to 21 in different sections).
• Increase administrative burden for providers and payers.
• Recreate many of the utilization and reimbursement challenges associated with former CPT code 92507.

Potential Downstream Medicaid Impact

In addition to concerns regarding Medicare reimbursement, there may be downstream implications for Medicaid programs and Managed Care Organizations (MCOs). Because many state Medicaid programs and MCOs adopt Medicare HCPCS codes and payment methodologies, some stakeholders are concerned that widespread adoption of GSLPP could affect pediatric speech-language pathology practices beyond the Medicare population.

Potential concerns include:

• Different coding requirements between Medicare, Medicaid, and commercial payers.
• Additional documentation and administrative burden if some payers adopt GSLPP while others implement the new timed CPT code family.
• Potential reimbursement differences for pediatric speech-language pathology services depending on payer policies.

While Medicaid adoption is speculative at this stage and will vary by state and payer, practices serving significant pediatric populations should monitor developments closely if GSLPP is finalized.

Why This Matters

If finalized, GSLPP could create a separate Medicare payment pathway for pediatric speech-language pathology services that differs from the new CPT framework. Because ASHA is actively contesting both the creation of GSLPP and the application of MPPR to SLP services, these provisions may change before the Final Rule is released.

8. MIPS and Quality Reporting Changes Continue

CMS is proposing broader changes to move clinicians away from traditional MIPS reporting toward value-based pathways.

ENT Impact

• Practices participating in MIPS should review proposed measure changes.
• Continued transition toward MVP-based reporting will require planning and preparation.

9. Comment Period Is Open

• Proposed Rule Released: July 14, 2026
• Federal Register Publication: July 16, 2026
• Comment Deadline: September 14, 2026, at 11:59 PM ET
• Expected Final Rule: November 2026
• Effective Date: January 1, 2027

Additional Resources

• CMS Proposed Rule (CMS-1848-P): View Proposed Rule
• CMS Fact Sheet: View Fact Sheet
• Official Comment Docket: Submit or Review Comments
• Federal Register Publication: View Federal Register Notice

Submit a comment

• Official CMS comment docket (CMS-2026-2377)
• AAO-HNS advocacy campaign on same-day E/M visits and procedures

Read the source material

• CMS Proposed Rule (CMS-1848-P)
• CMS fact sheet on the CY 2027 Physician Fee Schedule Proposed Rule
• Federal Register publication
• AAO-HNS summary of the CY 2027 MPFS Proposed Rule
• AMA National Advocacy Update
• ASHA analysis of the 2027 Medicare Part B Proposed Rule
  
  

Bottom Line for ENT Practices

The most significant proposals for ENT practices include the 50% payment reduction for additional same-day E/M and procedural services, the Practice Expense methodology changes, and the reimbursement changes affecting Audiology and Speech-Language Pathology services. Together, these proposals could have a substantial impact on reimbursement and patient access to care.

Audiology practices face additional reimbursement pressure from conversion factor reductions, Practice Expense methodology changes, and vestibular code valuation concerns. Speech-language pathology practices face significant proposed coding changes, including implementation of a new CPT code family, application of MPPR, and the proposed Medicare-specific GSLPP code.

Because GSLPP was developed outside the traditional CPT and RUC process, and ASHA is actively contesting both GSLPP and MPPR application to SLP services, these provisions could change before publication of the Final Rule. Practices with significant pediatric speech-language pathology services should also monitor potential downstream impacts on Medicaid and managed care payer policies.

Providers concerned about any aspect of the proposed rule should consider submitting comments to CMS before September 14, 2026, as stakeholder feedback can influence provisions included in the Final Rule. The formal public comment period closes September 14, 2026, at 11:59 PM Eastern Time.