The Centers for Medicare and Medicaid Services (CMS) recently released the proposed CY 2027 Physician Fee Schedule (PFS), which includes updates to the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS).
Several of the proposed changes could have significant impacts on Anesthesia practices. The following detailed summary highlights the key updates we’re watching closely.
Quick Take:
- The proposed rule lowers the 2027 conversion factor and changes the way PE RVUs are calculated and allocated. We are still evaluating the expected net impact on payment for anesthesia services.
- Alternative Payment Model status is tied to reimbursement and becoming increasingly important to CMS. A proposed change for 2027 affects Qualifying Participant (QP) determinations and will significantly impact anesthesia groups that provide services for multiple organizations or bill through multiple TINs.
- The proposed rule adds two new anesthesia MIPS quality measures and removes Measures 430 and 463.
- Traditional MIPS is proposed to end after 2028, completing CMS’s shift to the MIPS MVP program.
- The introduction of a new MIPS Core Measure framework may provide additional reporting opportunities for anesthesia practices.
- Beginning in 2027, the Ambulatory Specialty Model (ASM) will replace Traditional MIPS reporting for selected anesthesiologists and pain medicine physicians. The proposed rule includes some ASM revisions that are now under review.
Conversion Factor and Payment Adjustments
After increasing the conversion factor (CF) in 2026 for the first time in six years, CMS is lowering physician reimbursement again with a proposed decrease for 2027 for both the general CF and the anesthesia CF. As a reminder, there are also now two additional CF variances to be aware of, as CMS introduced a separate CF in 2026 for qualifying Alternative Payment Model (APM) participants. The proposed anesthesia CF for qualifying APM participants is $20.4165, which is a .89% decrease from CY 2026. The proposed CF decreases 1.38% to $20.2143 for non-qualifying physicians.
The 2027 rates reflect these key factors:
- The expiration of a temporary 2.5% update enacted for CY 2026
- A statutory increase in the Medicare Access and CHIP Reauthorization Act (MACRA) of 0.75% for qualifying APM participants and 0.25% for non-APM-qualifying physicians
- A 0.53% positive budget neutrality adjustment
- A 0.30% specialty-specific PE and malpractice adjustment, which applies only to anesthesia
PE Payment Changes
For anesthesia, reimbursement may also be impact by proposed changes to RVUs. CMS is proposing three major changes in 2027 to the way it calculates and allocates indirect practice expense (PE) RVUs:
- Reallocating indirect PE allocation to better align indirect costs with work RVUs and clinical labor inputs
- Phasing out the Indirect Practice Cost Index over a two-year transition because it relies on outdated specialty survey data
- Creating a new PE stabilizer adjustment that would mitigate short-term volatility by limiting annual increases or decreases in PE RVUs to +/-5 percent for most existing services
Net reimbursement impact for anesthesia is still under review.
Advanced APM Changes
With the addition of a higher CF for qualifying APM participants, one of the most significant proposals in the rule affects Qualifying Participant (QP) determinations.
Currently, QP status generally follows the individual clinician. Under the proposal, QP status would instead be tied to the participating TIN/NPI combination. This means APM-related benefits would only apply to services billed through the entity participating in the APM.
This change could have meaningful financial implications for anesthesia groups, particularly in organizations where physicians bill through multiple TINs or provide services across multiple facilities, health systems, or billing entities. If finalized, the shift from NPI-based to TIN/NPI-based QP determinations could alter the financial value of APM participation for some providers.
Merit-based Incentive Payment System (MIPS)
Traditional MIPS Is Scheduled to End After 2028
CMS plans to sunset Traditional MIPS after the 2028 performance year. Beginning in 2029, clinicians required to participate in MIPS would be reporting through a MIPS Value Pathway (MVP). (Clinicians already participating in eligible APMs would continue reporting through the appropriate APM reporting pathway.)
For anesthesia groups that have not yet evaluated MVP reporting options, the next two years may serve as the final transition period before Traditional MIPS reporting is no longer available.
New MVPs Continue CMS’s Expansion of Specialty Reporting
CMS is proposing three new MVPs for 2027:
- Diabetic Disease MVP
- Hypertension MVP
- Hospitalist MVP
While none of these MVPs are anesthesia-specific, the proposal reflects CMS’s continued commitment to expanding specialty-focused reporting pathways. CMS is also proposing to allow virtual groups to participate in MVP reporting beginning in 2029.
Quality Category Updates
CMS is proposing several changes within the Quality performance category, including:
- The addition of two new quality measures focused on prevention and chronic disease management
- Adoption of several QCDR measures into the MIPS CQM inventory
- Removal of 20 quality measures
- Substantive changes to 43 existing quality measures
Significantly, CMS is proposing two new anesthesia quality measures:
- Patient-Reported Experience with Anesthesia
This measure evaluates patients age 18 and older who are surveyed regarding their experience and satisfaction with anesthesia care and report a positive experience.
- Intraoperative Hypotension Among Non-Emergent Non-Cardiac Surgical Cases
This measure evaluates cases in which a patient’s mean arterial pressure (MAP) falls below 65 mmHg for a cumulative duration of 15 minutes or longer during non-emergent, non-cardiac surgery.
These measures will not be unfamiliar to many anesthesia practices, as both measures have historically been available through QCDR reporting:
- AQI Measure 48: Patient-Reported Experience with Anesthesia
- ePreop31: Intraoperative Hypotension Among Non-Emergent Noncardiac Surgical Cases
The proposal continues a broader CMS trend of incorporating established specialty-developed QCDR measures into the standard MIPS measure inventory.
CMS is also proposing the removal of two anesthesia measures:
- Measure 430: Prevention of Post-Operative Nausea and Vomiting (PONV) Combination Therapy
- Measure 463: Prevention of Post-Operative Vomiting (POV) Combination Therapy (Pediatrics)
This follows measure inventory changes that anesthesia groups have experienced over the past several years. While CMS is proposing two new anesthesia measures, the overall number of specialty-specific measure options remains limited, making measure selection and reporting strategy increasingly important. As always, anesthesia groups should review their currently reported measures to determine whether any specification updates could affect performance rates or reporting processes.
New MIPS Core Measure Requirement
CMS is proposing to replace the current outcome measure and high-priority measure requirements with a new MIPS Core Measure framework.
Under the proposal:
- Approximately 78 measures would be designated as Core Measures.
- Participants would be required to report at least one Core Measure if applicable.
- Small practices would be exempt.
- If no Core Measure is applicable, participants could submit an attestation and report an alternative measure instead.
- CMS proposes to allow topped-out MIPS Core Measures to continue receiving defined benchmarks rather than being subject to the traditional seven-point scoring cap. This could help preserve scoring opportunities and provide greater flexibility in measure selection for anesthesia and other specialties with a limited pool of available quality measures.
For anesthesia groups, the impact of this proposal will depend on the final Core Measure inventory and available specialty measure options.
Extreme and Uncontrollable Circumstances (EUC)
CMS is proposing to remove the requirement that automatic Extreme and Uncontrollable Circumstances (EUC) determinations rely specifically on PECOS data. This change would not affect the standard hardship application process but would provide CMS with greater flexibility when applying automatic EUC relief.
Performance Threshold Remains Unchanged
CMS is not proposing any changes to the MIPS performance threshold. The score required to avoid a negative payment adjustment remains 75 points, a threshold that has already been finalized through Performance Year 2028.
Improvement Activities
CMS is proposing:
- 6 new Improvement Activities
- 5 modified Improvement Activities
- 11 removed Improvement Activities
Many of the proposed additions focus on prevention, wellness, nutrition, and chronic disease management.
The Ambulatory Specialty Model (ASM)
Beginning in 2027, the Ambulatory Specialty Model will replace Traditional MIPS reporting for selected anesthesiologists and pain medicine physicians treating low-back-pain episodes in designated regions.
Participation is determined at the individual TIN/NPI-combination level, with no general opt-out option. Clinicians selected for ASM will be evaluated under ASM-specific quality, cost, and care-coordination measures. Payment adjustments will apply to Medicare Part B services based on performance.
Although the ASM program was approved under the CY 2026 PFS Final Rule, the CY 2027 proposed rule includes several ASM revisions, including changes to TIN-transition rules, quality measures, improvement-activity reporting, scoring, and payment-adjustment portability.
ASA has raised concerns about measure alignment, reporting burden, and whether anesthesiologists will have a realistic opportunity to earn positive adjustments. Stakeholders should consider commenting on attribution, applicable measures, implementation, and downside-risk protections before the comment period closes on September 14, 2026.
Looking Ahead
While the 2027 rule is still in the proposal stage, it provides a clear view of where CMS is heading. For anesthesia practices, the addition of familiar QCDR measures into MIPS may create new reporting opportunities, while the proposed Advanced APM and MIPS structural changes could have longer-term operational and financial implications. Practices should begin evaluating the potential impact now.
The public comment period is open through September 14, 2026, with a final rule expected later this fall. Stakeholders should consider submitting comments on the proposed rule to share operational concerns, financial impact questions, and recommendations for implementation.
As always, the Ventra Health team will be monitoring the changes and planning for all issues that will impact our clients. Additional information and resources are available in our general overview of the CY 2027 Physician Fee Schedule Proposed Rule.
If you have questions about how these changes will impact your practice, please don’t hesitate to contact us.
