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July 28, 2026

Each July, the Centers for Medicare & Medicaid Services (CMS) releases its proposed rule for the Medicare Physician Fee Schedule, which sets out how physicians are paid for their work with Medicare beneficiaries.

The proposed rule for 2027 includes a number of changes affecting neurology. Our full summary is available online, but keep reading for some of the highlights—including payment, coding changes, the end of traditional MIPS reporting, and more.

AAN advocacy leaders and staff are working on our formal response to the proposals, which we’ll send to CMS during the comment period. The agency will then release its final rule this fall.

Neurologist pay

CMS projects its proposals will lead to no change in total payments to neurology as a specialty, broadly. However, that projection doesn’t include the expiration of the temporary 2.5% increase approved by Congress in the One Big Beautiful Bill Act in 2026. It also doesn’t include the annual statutory increase of 0.75% for qualifying Alternate Payment Model (APM) participants and 0.25% for non-qualifying participants. 

This means action from Congress is needed to protect neurologists and other physicians from a pay cut. If Congress doesn’t extend the temporary increase for 2027, the Medicare conversion factor will be reduced by 1.19% (for qualifying APM participants) or 1.68% (for non-qualifying participants). Annual cuts to the Medicare Physician Fee Schedule are an ongoing problem: CMS can’t unilaterally add funding, so short-term congressional fixes are always needed. As in previous years, the AAN will advocate for action from Congress to prevent the cut before it goes into effect.

We’ll also keep working with legislators to find a long-term solution through Medicare payment reform—and new legislation introduced in the House would do just that. Visit our to contact your representatives about the Patients First Act, a bipartisan bill that would provide an annual inflationary payment update, reform outdated budget neutrality policies, establish a lookback period to improve the accuracy of utilization assumptions, and modernize quality reporting requirements.

MIPS sunsetting

CMS plans to phase out the traditional MIPS reporting option after the Calendar Year 2028 performance period, moving fully to MIPS Value Pathways (MVPs), which the agency described in a press release as more clinically meaningful and specialty focused. 

As part of this proposal, CMS aims to modify all 27 existing MVPs to include MIPS core measure selections, expand on clinical concepts or capture additional specialties, address maintenance requests from the public, and remove some measures and activities. Three new MVPs would also be added (Diabetic Disease, Hypertension, and Hospitalist), and the Rehabilitative Support for Musculoskeletal Care MVP would be renamed to simply Rehabilitative Support.

In the traditional MIPS option, CMS isn’t proposing any changes to the category weights or performance threshold. Performance categories will be maintained at 30% for Quality, 30% for Cost, 15% for Improvement Activities, and 25% for Promoting Interoperability. The performance threshold will stay at 75 points.

Coding changes

CMS previously finalized separate coding and payment for code G2211, an add-on code associated with visit complexity for office or outpatient evaluation and management (E/M) service. The agency wants to transition this code to a two-digit modifier that can be added to the associated E/M base code. This modifier would increase the payment of the associated E/M code by 16%, instead of a flat rate. 

Additionally, new or revised code sets will be available starting in the new year for rotational vestibular assessment, testing of autonomic nervous system function, and unattended sleep studies.

Remote supervision and telehealth

Due to practice patterns that evolved during the COVID-19 pandemic, CMS previously finalized policy that allowed teaching physicians to have a virtual presence in all geographic residency training locations, but only when the teaching physician, resident, and patient are all in different locations. In response to feedback from the AAN and other stakeholders, CMS is proposing to simplify this policy and allow teaching physicians to bill for services involving residents when either the teaching physician or resident is in the same physical location as the beneficiary. 

Other key telehealth issues need further work. Flexibilities that began during the pandemic have been extended by Congress several times, including in 2026 through government funding legislation. Importantly, these flexibilities allow CMS to pay for telehealth visits that take place in the beneficiary’s home or through audio-only services. The latest extension applies through the end of 2027, but further congressional action is needed to extend it further or make it permanent.  

Practice expense calculations

Another proposed change would modify how CMS calculates practice expense relative value units (RVUs) as it aims to reduce reliance on outdated practice expense data. The agency wants to phase out the final step in its existing process and instead introduce a “practice expense stabilizer” to ease short-term volatility without anchoring values to a specific point in time. 

The agency says it will continue transitioning away from reliance on American Medical Association (AMA) surveys that estimate physician work, direct practice expense inputs, and overall practice expense for calculating payment rates. Instead, it says it plans to implement an approach that relies on more objective, routinely updated, and auditable cost data.

What’s next?

AAN advocacy leaders and staff meet regularly with CMS leadership throughout the year. We also submit comment letters on key proposals and join with other stakeholders to amplify neurologists’ voices. Our formal response to the proposed rule will be available before CMS’s mid-September deadline. We expect the agency to release its final rule for 2027 in November.

If you’re interested in learning more about the proposals affecting neurology, dig into our full, detailed summary. And to stay updated on new comment letters and advocacy updates, read Capitol Hill Report, a biweekly newsletter emailed to US members and posted online.