Billing/RCM

2027 Medicare Physician Fee Schedule: What Behavioral Health Billing Teams Must Change Before January 1

Medicare’s 2027 physician fee schedule cuts payment per service and changes how several behavioral health claims must be built, and most changes take effect January 1. CMS released the final rule (CMS-1848-F) on November 4, and it was published in the Federal Register on November 9 (91 FR 70992).

The headline is a 2.31% cut, but the bigger exposure sits at the claim level: new modifiers, a same-day payment rule and telehealth edits that can quietly turn paid claims into denials. Treat this as a December project, not a January one.

This guide covers only the provisions that change what billing teams submit or collect. Everything below applies to Medicare Part B. If Medicare is a small share of your revenue, start with sections 1 and 4. Sections 2, 3 and 5 matter most to practices with prescribers, TMS or collaborative care. Commercial payers set their own rules, though some follow CMS’s lead.

1. Medicare’s conversion factor drops 2.31% in 2027

The conversion factor falls from $33.40 to $32.63 for most clinicians, and from $33.57 to $32.95 (1.83%) for those in qualifying alternative payment models. Congress’s one-time 2.50% increase for 2026 expires, and small statutory updates do not cover the gap. Congress could act again, as it did for 2026, so keep a second scenario ready.

Code-level payments will not all move by the same percentage. CMS projects a significant positive RVU impact for clinical psychologists and clinical social workers from its code valuation and practice expense changes, and 2027 is the final year of the four-year increase to psychotherapy work RVUs. Rebuild your Medicare fee schedule from the final Addendum B on the CMS-1848-F page, which CMS updated on November 5, instead of applying a flat 2.31% cut.

2. G2211 is retired and modifier B1 replaces it

For dates of service on or after January 1, 2027, G2211, the visit complexity add-on, is no longer a separate code. It becomes modifier B1 on the office, outpatient, home or residence E/M line, valued at 16% of the E/M’s total RVUs. CMS expects minimal overall impact, because volume billed under G2211 moves to the modifier. Modifier B2 pays 32% and is limited to practitioners in a Shared Savings Program ACO or the LEAD Model. This affects psychiatrists, psychiatric nurse practitioners and physician assistants who bill E/M visits for patients they follow over time.

Three billing points matter:

  • Visit mix decides the outcome. G2211’s flat 0.52 RVUs was worth 29% of a 99212 but only 9% of a 99215. At 16%, B1 breaks even on a visit worth about 3.25 total RVUs. Lower-valued visits get less than they did, and higher-valued visits get more.
  • Modifier 25 blocks it. B1 and B2 are not payable when the E/M carries modifier 25, except on the same day as a preventive service. CMS considered changing this and did not.
  • Price it before you forecast. CMS posted a file mapping B1 and B2 values to each E/M level on the CMS-1848-F page. Run your actual 99213, 99214 and 99215 volume through it.

3. A same-day E/M reduction may reach TMS billing

Starting January 1, when an office or outpatient E/M is billed on the same day as a procedure with a 0-day global period, Medicare pays the highest-valued service in full and reduces every other service that day by 20%. It applies when the same practitioner, or one of the same specialty in the same group, furnishes both. CMS narrowed the proposal after comments: it was 50% and also covered 10- and 90-day global procedures.

The policy does not name any behavioral health codes, and the rule does not list which codes carry a 0-day global. If you bill TMS, ECT or other procedures, check each code’s global indicator in Addendum B. Public fee schedule data lists TMS (90867 through 90869) with a 0-day global, so confirm it first. If it applies, a TMS-day E/M could take two hits, because B1 is also not payable on an E/M billed with modifier 25.

Do not move E/M visits off treatment days to avoid the reduction. CMS calls scheduling to maximize payment inappropriate and plans to watch for it through claims edits and medical review. Audit modifier 25 use on TMS days, and make sure each E/M documents a significant, separately identifiable service.

4. Medicare telehealth claims need modifiers BB and BC

Starting January 1, 2027, Medicare telehealth claims need modifier BB or BC where they apply. Neither changes payment. BB goes on telehealth furnished through a virtual platform when the practitioner contracts with, or has a payment arrangement with, the entity that owns the platform. BC goes on telehealth furnished incident to a physician’s or practitioner’s professional service.

The rule repeats the statutory definition without adding detail, and CMS says guidance will appear on its telehealth page. Map which providers use which platform arrangements now, build the modifier edits into your claim scrubber, and ask your MAC how BB applies to a paid platform subscription.

Two dates sit behind this. Medicare telehealth flexibilities run through December 31, 2027. The in-person requirement for tele-mental health returns January 1, 2028: a visit within six months before the first telehealth service and at least every 12 months afterward, unless practitioner and patient document that the risks outweigh the benefits.

5. Collaborative care (CoCM) and SBIRT pay more in 2027

Two behavioral health services gain value in 2027, and both are worth adding to your charge capture review.

  • Collaborative care (CoCM). CMS finalized larger increases than it proposed. The work RVU for 99492 rises from 1.88 to 3.25, 99493 from 2.05 to 2.56, and 99494 from 0.82 to 1.28. CMS also raised the behavioral health care manager labor rate from $0.57 to $0.70 per minute. For groups that partner with primary care, this improves the economics of offering collaborative care.
  • SBIRT and tobacco cessation. CMS applied the full 19.1% work RVU increase to G0396, G0397, G2011, 99406 and 99407, so these short, frequent services pay more.

Your billing checklist before January 1

  1. Rebuild your 2027 Medicare fee schedule from the latest Addendum B, starting with your top 10 codes by volume.
  2. Retire G2211 for 2027 dates of service, add B1 (and B2 if you qualify) to charge masters, templates and claim edits, and price your 99213 to 99215 mix at 16%.
  3. Confirm global indicators for your procedure codes and audit modifier 25 use on TMS and other procedure days.
  4. Add BB and BC edits for telehealth claims and document each provider’s platform arrangement.
  5. Confirm each commercial payer’s 2027 position before you copy any of these changes into its rules.

Frequently asked questions

When do the 2027 Medicare fee schedule changes take effect?

January 1, 2027. CMS released the final rule on November 4, 2026, and it was published in the Federal Register on November 9 (91 FR 70992).

What replaces G2211 in 2027?

Modifier B1, valued at 16% of the E/M’s total RVUs. Modifier B2 (32%) is limited to ACO and LEAD Model practitioners. Neither is payable on an E/M billed with modifier 25, except alongside preventive services.

Do modifiers BB and BC change Medicare telehealth payment?

No. They are required on qualifying claims starting January 1, 2027, but CMS says they have no payment implications.

Terms used in this post: RVU is a relative value unit, the points Medicare uses to price a service. E/M is an evaluation and management visit. CoCM is the psychiatric collaborative care model. SBIRT is screening, brief intervention and referral to treatment. TMS is transcranial magnetic stimulation. A MAC is a Medicare Administrative Contractor.

The conversion factor is out of your hands, but your claim edits are not. If you want help pressure-testing your Medicare mix or claim edits, reach out to me or ClinicMind’s behavioral health team.

Sources

This post is general information, not legal or coding advice. Confirm requirements with your Medicare Administrative Contractor and payers.

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