CY2027 Physician Fee Schedule: A Wound-Care Analysis
What the CY2027 fee schedule means for wound care
On July 16, 2026, CMS published the CY2027 Physician Fee Schedule proposed rule (CMS-1848-P). Open Wound Research has reviewed all 716 pages and translated the provisions that touch wound care into plain language, organized by how they affect each practice model.
Comment period closes September 14, 2026
This is an independent analysis from Open Wound Research: not legal, billing, or coding advice, and not affiliated with or endorsed by CMS. Analytical commentary is boxed and marked “OWR Analysis”. The official rule remains the authoritative source for all codes and payment figures.
The headline: this rule splits wound care by setting
The most significant pattern in this proposed rule is that it does not treat all wound care the same. Where and how care is delivered largely determines whether CY2027 is a cut or a wash. A second axis runs alongside it: who provides the care also moves payment. An independent physician and a hospital-employed one can be paid differently for the same facility service, since CMS is weighing an “employed physician” modifier that would cut employed physicians’ practice-expense pay (see SNF & mobile wound care); specialty and ACO or APM affiliation shift payment further.
All figures on this page are year-over-year changes from CY2026, not cumulative changes across multiple years.
Office & wound-center practices: most affected
- The proposed modifier -25 policy would pay the most expensive same-day service at 100% and cut the E/M and any other procedure to 50%, directly halving the “E/M + same-day debridement or skin-substitute application” claims these practices depend on.
- Combined specialty impacts (all CY2027 policies vs CY2026, RIA Table D-B5) concentrate here: dermatology −9%, podiatry −4%, plastic surgery −3%. These figures reflect the whole rule, not modifier -25 alone; see Payment impact for the policy-by-policy breakdown.
- Layered on top: the −1.68% conversion-factor decrease from CY2026.
Mobile & SNF-based wound care: comparatively less affected
- CMS proposes to equalize skilled-nursing-facility E/M payment, reversing a CY2026 cut on visits to Part A (POS 31) patients.
- The modifier -25 reduction, as written, spares nursing-facility E/M codes.
- Facility-setting impacts skew positive: nurse practitioner +6%, geriatrics +7%, family-practice facility +3%.
Separately from the CY2027 rule, a standing 2% Medicare sequestration reduces every Medicare fee-for-service payment at the claim level, applied after the fee schedule. It applies in both CY2026 and CY2027, so it is not part of the year-over-year figures above; it is a constant reduction in the actual dollars a practice receives. See Payment impact.
Explore the analysis
E/M & Modifier -25
The 50% same-day reduction, and how G2211 becomes the MOD1 / MOD2 percentage modifiers, the most significant issue for wound-visit billing.
Mobile & SNF Wound Care
Nursing-facility E/M rate equalization and why mobile providers are comparatively less affected.
Procedures & New Codes
Skin cell suspension autograft (15X19–15X22) and real-time fluorescence wound imaging (976XX).
“Misvalued” Wound Services
UltraMIST / ultrasonic therapy (97610) supply cut, autologous PRP (G0465), and hyperbaric oxygen (G0277).
Skin Substitutes
The flagship change: national pricing of non-sheet-form skin substitutes at sheet-form rates, continuing the CY2026 payment overhaul.
Payment Impact
The CY2027 conversion factor and the specialty-by-specialty impact table.
How to use this site
Each analysis page follows the same structure: what CMS actually proposed (cited to the rule), why it matters for wound care, a deep-dive on the implications for each practice model (office-based, mobile wound care including skilled nursing, and wound care center), and considerations for providers and manufacturers. The About & How to Comment page covers sourcing and the comment mechanics.