On September 11, the Endocrine Society formally submitted a comprehensive set of comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed rule for the Calendar Year 2027 Medicare Physician Fee Schedule (MPFS). This annual regulatory update, which dictates the reimbursement landscape for services provided under Medicare Part B, remains a focal point for medical specialty societies seeking to ensure the financial viability of clinical practice and the continued accessibility of specialized care for patients. The Society’s response highlights a complex dichotomy in the proposed rule: while specific adjustments for the endocrinology specialty suggest a 2.5% increase in reimbursement, an overarching 2.5% reduction in the conversion factor across all physician services threatens to negate these gains, resulting in a net-zero or negative impact on many practices.
The Endocrine Society’s advocacy efforts, coordinated through its Clinical Affairs Core Committee (CACC), underscore the growing friction between rising operational costs and the federal government’s budget-neutrality requirements. As physicians nationwide grapple with inflationary pressures, the Society is intensifying its call for congressional intervention to decouple Medicare updates from arbitrary budget caps and instead tie them to the Medicare Economic Index (MEI).
The Looming Conversion Factor Crisis and Inflationary Pressure
At the heart of the Endocrine Society’s concerns is the proposed reduction to the conversion factor—the dollar multiplier applied to Relative Value Units (RVUs) to determine the final payment for a medical service. For 2027, CMS has proposed a 2.5% decrease in this factor, a move necessitated by statutory budget-neutrality requirements that mandate any increase in spending in one area of the fee schedule be offset by cuts elsewhere.
This systemic issue has prompted the Endocrine Society to join a broader coalition of medical organizations urging Congress to pass permanent legislative reforms. The Society argues that the current model is unsustainable, as it does not account for the rising costs of labor, medical supplies, and rent. According to data from the American Medical Association (AMA), when adjusted for inflation in practice costs, Medicare physician payment has effectively declined by nearly 30% since 2001. The Society’s letter emphasizes that without an annual update tied to the MEI—a measure of the inflation faced by physicians—the gap between the cost of delivering high-quality endocrine care and federal reimbursement will continue to widen, potentially leading to a reduction in the number of providers accepting Medicare patients.
Advocacy Success: Fine Needle Aspiration and Portable Ultrasound
Despite the concerns regarding the conversion factor, the 2027 proposed rule contains several provisions that the Endocrine Society views as significant victories for the specialty. Chief among these is the proposal to create a new practice expense equipment item for Fine Needle Aspiration (FNA).
The proposed code, ER130, designated as "Fine Needle Aspiration portable ultrasound," represents the culmination of multi-year advocacy efforts by the Endocrine Society in collaboration with other medical organizations. FNA is a critical diagnostic tool used by endocrinologists to evaluate thyroid nodules and other suspicious masses. The procedure increasingly relies on portable ultrasound technology to ensure accuracy and patient safety.
Previously, the practice expense inputs for FNA did not adequately reflect the cost of the high-tech portable ultrasound units used in modern clinical settings. By advocating for the inclusion of ER130 at the Current Procedural Terminology (CPT) and Relative Value Scale Update Committee (RUC) levels, the Endocrine Society has moved CMS toward a reimbursement model that more accurately covers the overhead costs associated with this essential service. The Society’s comments strongly support this change, noting that it will help sustain the infrastructure necessary for endocrinologists to perform these procedures in-office rather than referring patients to more expensive hospital-based settings.
The Controversy Over G2211 and the Proposed MOD1 Transition
One of the most contentious aspects of the 2027 proposed rule is the plan to restructure the reimbursement for complex, longitudinal care. CMS has proposed deleting the G2211 complex care code—a relatively new add-on code designed to compensate physicians for the "office-based medical home" work inherent in managing chronic conditions—and replacing it with a new modifier, tentatively labeled MOD1.
Under the proposal, MOD1 would be appended to an Evaluation and Management (E/M) code, resulting in a 16% increase in the value of the reported CPT code. While this might appear to be a streamlined approach to rewarding complex care, the Endocrine Society has expressed deep reservations regarding its implementation.
The primary concern lies in the impact on Work RVUs, particularly for endocrinologists practicing within large hospital systems or academic medical centers. Many of these institutions utilize compensation models based strictly on the accumulation of Work RVUs. Because modifiers are often treated differently than standalone codes in these internal accounting systems, the transition from G2211 (which carries its own RVU weight) to MOD1 could result in a significant loss of recognized "work" for the physician, even if the total dollar amount paid to the system remains similar.
In its letter to CMS, the Endocrine Society urged the agency to retain the G2211 code. The Society argues that G2211 accurately captures the cognitive labor and long-term relationship-building required for endocrinologists to manage complex diseases like Type 1 diabetes, osteoporosis, and adrenal disorders. Replacing it with a modifier, the Society contends, risks devaluing the specialty’s expertise and complicating the financial reporting structures of large healthcare organizations.
Protecting the Integrity of Modifier 25
The Endocrine Society also used its comment letter to push back against a proposal that would reduce payments when Modifier 25 is used. Modifier 25 is employed when a physician performs a significant, separately identifiable E/M service on the same day as a procedure or other service.
CMS has proposed reducing the reimbursement for the E/M component in these scenarios under certain circumstances, citing concerns about overlapping practice expenses. However, the Endocrine Society argues that such a reduction would unfairly penalize specialists who provide comprehensive care in a single visit. For patients with endocrine disorders—many of whom travel long distances to see a specialist—the ability to receive an evaluation and a necessary procedure (such as a biopsy or an injection) in one appointment is a matter of both convenience and clinical necessity. Reducing the payment for these services could incentivize physicians to schedule separate appointments, increasing the burden on patients and overall costs to the healthcare system.
Chronology of the 2027 MPFS Rulemaking Process
The submission of comments on September 11 is a critical stage in the federal rulemaking timeline. The process for the 2027 Medicare Physician Fee Schedule follows a structured annual cycle:
- Early July 2026: CMS releases the Notice of Proposed Rulemaking (NPRM), detailing proposed changes to payment rates, quality programs, and coding structures for the upcoming year.
- July–August 2026: Medical societies, such as the Endocrine Society, review thousands of pages of regulatory text. The Clinical Affairs Core Committee (CACC) analyzes the potential impact on practitioners.
- September 11, 2026: The public comment period closes. This is the final opportunity for stakeholders to submit data-driven arguments to influence the final rule.
- October 2026: CMS reviewers analyze thousands of comments from physicians, hospital associations, patient advocacy groups, and the public.
- Early November 2026: CMS is expected to release the Final Rule. This document will confirm the payment rates and policy changes that will take effect on January 1, 2027.
- January 1, 2027: The new fee schedule officially goes into effect.
Broader Implications for the Endocrinology Specialty
The outcome of this rulemaking cycle carries significant weight for the future of the endocrinology workforce. Endocrinology remains one of the lower-compensated specialties in medicine, despite the high complexity of the patient population and the long-term management required for chronic endocrine conditions.
If the 2.5% specialty increase is upheld but the conversion factor cut is not mitigated by Congress, the specialty faces a period of stagnation. The Endocrine Society’s emphasis on "work RVUs" reflects a broader trend in physician advocacy: the need to ensure that the "value" of a physician’s time and expertise is correctly quantified in an era of increasing administrative burden.
Furthermore, the focus on FNA and ultrasound equipment reflects the shift toward office-based procedures. By securing better reimbursement for equipment like the portable ultrasound (ER130), the Society is helping to ensure that private practices can compete with hospital outpatient departments, which often receive higher facility fees for the same procedures.
Conclusion and Next Steps
The Endocrine Society’s detailed response to the CMS 2027 proposed rule serves as a vital defense of the specialty’s economic and clinical interests. By advocating for the preservation of G2211, the fair valuation of FNA services, and the protection of Modifier 25, the Society is working to stabilize a reimbursement environment that many providers find increasingly volatile.
The Society has extended its gratitude to the members of the Clinical Affairs Core Committee for their technical expertise and collaboration during the drafting of the comment letter. As the medical community awaits the release of the final rule in November, the focus shifts toward Capitol Hill, where the Endocrine Society and its allies will continue to lobby for a permanent, inflationary-adjusted update to the Medicare Physician Fee Schedule.
The full text of the Society’s comment letter, detailing the specific data and clinical arguments provided to CMS, is available for public review on the Endocrine Society’s advocacy website. Stakeholders are encouraged to remain engaged as the final regulations take shape, determining the financial landscape for endocrine care in 2027 and beyond.
