Reimbursement Intelligence · CY 2027 Final Rule

The 2027 Medicare Reset: Two Conversion Factors, One Direction

What the CY 2027 Physician Fee Schedule final rule, the MIPS-to-MVP transition, and the telehealth timeline mean for physical therapy practice economics — and for what a buyer will pay.

MIHAMA
Physical Therapy
Investment Banking
Mihama Market Intelligence Series · No. 07Current as of November 4, 2026 · Sources listed at end

Today, November 4, 2026, CMS released the Calendar Year 2027 Medicare Physician Fee Schedule final rule. For the physical therapy practice owner, the headline is blunt: the conversion factor that most PTs are paid on falls 2.31% on January 1, 2027, erasing much of the one-year bump Congress provided for 2026.1 At the same time, CMS locked in a decade-long march away from traditional MIPS and toward specialty-specific quality pathways and outcome measurement.2

For owners contemplating a sale in the next 12–36 months, these changes are not abstract policy. Buyers model Medicare exposure line by line, stress-test it, and multiply every dollar of lost EBITDA by the deal multiple. This paper explains exactly what changed, what it means at the CPT-code level, and how to position your practice before a buyer's Quality of Earnings team does the math for you.

The Numbers
The CY 2027 Final Rule at a Glance
$32.63
2027 Non-QP CF
−2.31% vs. $33.40 in 2026 — the rate most PTs are paid on
$32.95
2027 QP CF
−1.83% vs. $33.57 — Advanced APM qualifying participants only
2031
Traditional MIPS Ends
MVP-only reporting begins with the CY 2031 performance period
12/31/27
PT Telehealth Runway
Medicare telehealth eligibility for PTs extended by statute
Section 01
Why the Conversion Factor Fell — Decomposing the −2.31%

The 2027 cut is not a new CMS policy decision so much as the expiration of a temporary one. Public Law 119-21 (which CMS refers to as the "Working Families Tax Cut" legislation) added a one-year 2.5% increase to the 2026 conversion factor. That increase sunsets on December 31, 2026, and current law requires CMS to remove it.1 Three components produce the final 2027 figures:

ComponentNon-QP (most PTs)QP (Advanced APM)What It Is
Statutory MACRA update+0.25%+0.75%Fixed by law beginning in 2026; the source of the two-tier system
Work RVU adjustment−0.12%−0.12%Budget-neutrality offset for changes to work RVUs on certain codes
Expiration of the 2026 one-year increase−2.44%−2.44%Removing a 2.5% multiplier (÷1.025) equals a −2.44% change
Net change, CY 2027−2.31%−1.83%$33.4009 → $32.63 (non-QP); $33.5675 → $32.95 (QP)
Arithmetic check: 1.0025 × 0.9988 ÷ 1.025 = 0.9769 (−2.31%); 1.0075 × 0.9988 ÷ 1.025 = 0.9817 (−1.83%). CMS publishes the 2027 factors to two decimal places in its fact sheet; four-decimal values will appear in the final rule addenda.1
−9.6%
The Long View: 2020 to 2027. The physician fee schedule conversion factor was approximately $36.09 in 2020 and fell to $32.3465 by 2025 — a decline of more than 10% while practice costs rose.9 2026 brought the first increase in five years (+3.26% for non-QPs, which APTA estimates translated into an average +1.75% for physical therapy after RVU changes).3,4 At $32.63, the 2027 non-QP factor sits roughly 9.6% below its 2020 level in nominal dollars — before any adjustment for inflation.
Section 02
Two Conversion Factors: Why Nearly Every PT Practice Gets the Lower One
⚖︎
The Rule

A Statutory Two-Tier System Began in 2026

Beginning in CY 2026, MACRA requires separate conversion factors for clinicians who are Qualifying APM Participants (QPs) in Advanced Alternative Payment Models and for everyone else. QPs must meet participation thresholds in models that carry accountability for quality and cost.1

The Reality

Independent PT Practices Rarely Qualify on Their Own

The overwhelming majority of outpatient PT, OT, and SLP practices do not meet QP thresholds independently.9 For a typical private practice, the relevant 2027 rate is $32.63. The QP premium is roughly 1.0% in 2027 ($32.95 vs. $32.63) — small today, but it compounds annually because the QP statutory update (+0.75%) exceeds the non-QP update (+0.25%) every year.

The Strategic Read

CMS Is Paying for Accountability

The widening gap is a deliberate policy signal: Medicare is rewarding participation in accountable-care arrangements. For PT practices, the practical paths to that upside run through ACO and hospital-system partnerships and outcome-aligned models such as CMMI's ACCESS model, which includes a musculoskeletal track.

The Buyer's Read

Platforms With ACO Ties Will Model It

Hospital-affiliated and ACO-aligned buyers can underwrite a different Medicare trajectory than a stand-alone practice. When Mihama runs a process, we identify which bidders can credibly capture accountable-care economics — because those bidders can often justify a higher price for the same EBITDA.

Section 03
What Actually Hits PT Codes: The Conversion Factor Is Only Half the Story

Medicare payment for a CPT code equals its total RVUs (work, practice expense, malpractice — geographically adjusted) multiplied by the conversion factor. A practice's real 2027 rate change depends on its CPT mix, not the headline. Three structural factors matter most for therapy:

01
Efficiency Adjustment · Time-Based Codes

Most Core PT Codes Were Shielded From the 2.5% "Efficiency Adjustment"

What CMS Did

For 2026, CMS finalized a 2.5% "efficiency adjustment" that reduces work RVUs and intraservice time for most non-time-based services. Time-based services were excluded, and after comments from APTA and others, the final rule also removed several therapy codes from the adjustment list, including 97032–97036, 97113, 97124, 97140, and 97533.5,14

✓︎ What It Means

Timed codes such as 97110, 97140, and 97530 — the backbone of most PT revenue — sit outside the adjustment. Untimed modalities such as unattended electrical stimulation (billed to Medicare as G0283; 97014 for most commercial payers) and mechanical traction (97012) are the exposure.14 Practices with heavy untimed-modality billing carry more 2026–2027 rate risk than practices built on skilled, timed intervention.

02
Practice Expense Methodology · 2027

The 2027 Practice-Expense Overhaul Could Offset Part of the Cut — Confirm Before You Budget

What CMS Finalized

The final rule phases out the indirect practice cost index (IPCI) over two years, replaces it with a "PE stabilizer" to limit volatility, and allocates indirect practice expense on both work RVUs and clinical-labor PE RVUs for most codes.1

⚠︎ The Uncertainty

When the rule was proposed in July, APTA reported that CMS estimated physical therapy codes could see an overall payment increase of roughly 1–3%, largely from practice-expense changes; APTA's own September analysis concluded that the proposal's long-term payment gains were larger still.15,7 The final rule modified the PE policy and finalized a deeper conversion-factor cut than proposed (−2.31% vs. −1.68%).1,6 The net effect for therapy must be confirmed against the final-rule specialty impact tables and code-level RVUs — not assumed.

Mihama's Recommendation: Re-price your top 15 CPT codes (for most practices, the large majority of Medicare charges) using final 2027 RVUs for your locality, then weight by your actual 2026 unit volumes. That single exercise converts a headline into a defensible budget — and it is exactly the analysis a buyer's QoE team will run.

03
Layered Payment Reductions · Still in Force

The Reductions That Stack on Top of the Conversion Factor

Policies That Compound
  • MPPR: the practice-expense component of the second and subsequent "always therapy" units on a date of service is reduced 50%.
  • CQ/CO differential: services furnished in whole or in part by a PTA (CQ) or OTA (CO) are paid at 85% of the fee schedule amount.
  • Sequestration: the 2% Medicare sequester continues to reduce claim payments.
Thresholds to Track
  • KX modifier threshold: $2,480 for PT and SLP combined (and $2,480 for OT) in 2026.8 CMS proposed $2,540 for 2027 based on the 2.5% MEI update — verify the final figure in the CY 2027 therapy transmittal.8
  • Targeted medical review threshold: $3,000, scheduled to begin MEI indexing in 2028.8
Section 04
What a Rate Change Does to Your Enterprise Value

Because Medicare rate changes flow almost entirely to EBITDA (your staffing, rent, and overhead do not shrink when the fee schedule does), every percentage point is magnified by the deal multiple. The illustration below assumes a practice with $1.2 million of annual Medicare Part B fee-for-service revenue and assumes costs do not change. Because buyers value the practice on a multiple of EBITDA, each dollar in the last column is magnified into several times that amount in enterprise value at closing.

Scenario (Net Medicare Rate Change, 2027 vs. 2026)Rate ChangeAnnual Revenue & EBITDA Impact
Conversion-factor cut with no RVU offset−2.31%−$27,720
Partial practice-expense offset−1.00%−$12,000
Full offset (flat year)0.00%$0
RVU gains exceed CF cut+1.00%+$12,000
Illustrative only. Assumes costs are unchanged and the full revenue change flows to EBITDA. Actual results depend on CPT mix, locality (GPCI), PTA utilization, Medicare Advantage contract terms (many MA contracts reference the fee schedule), and any congressional action before January 1, 2027.
Section 05
The End of Traditional MIPS — and the Rise of Outcome Measurement
05
Quality Payment Program · Final CY 2027 Policy

MVP-Only Reporting Is Coming. You Have Until the End of 2030.

What Was Finalized Today

CMS will sunset the traditional MIPS reporting option beginning with the CY 2031 performance period. Clinicians have through CY 2030 to move to MIPS Value Pathways (MVPs) or Advanced APMs — two more years than the July proposal, which would have ended traditional MIPS after 2028.2

Starting with the CY 2027 performance period, clinicians must report at least one specialty-specific "Core Measure."2 CMS also finalized three new MVPs (diabetes, hypertension, hospitalist). The rehabilitation-relevant pathway is the Rehabilitative Support for Musculoskeletal Care MVP.

⚠︎ The Money at Stake

PTs, OTs, and SLPs in private practice who exceed all three low-volume thresholds — more than $90,000 in Part B allowed charges, more than 200 Medicare beneficiaries, and more than 200 covered professional services — must participate. The performance threshold is 75 points through the 2028 performance year, and adjustments range up to ±9%, applied two years after the performance year (2027 performance drives 2029 payments).10

CMS also proposed replacing older FOTO-based functional status measures with new PROMIS-based functional outcome measures for neck, back, upper-extremity, lower-extremity, and knee patients.13 Confirm which were finalized before selecting 2027 measures.

Why It Matters for Valuation: A −9% MIPS adjustment on Medicare revenue is a material, known future liability that a buyer will price. Conversely, a practice with clean MVP reporting and patient-reported outcome data has a defensible quality story for payers, hospital partners, and acquirers. Outcome data is moving from "nice to have" to the currency of value-based contracting.

Section 06
Remote Therapeutic Monitoring and Telehealth: The 2027 Ground Rules
RTM · 2026 Expansion

New Codes Lowered the Bar to Bill

For 2026, CMS added RTM codes including 98985 (musculoskeletal device supply for 2–15 days in a 30-day period) and 98979 (treatment management with at least one real-time interactive communication), addressing the old "16 days or nothing" problem. They are "sometimes therapy" codes and must be part of a therapy plan of care when furnished by PTs.11

RTM · 2027 Final Rule

Tighter Guardrails Start January 1

CMS finalized that RTM is furnished only to established patients and that a separately reportable initiating visit is required when RTM begins. The proposed requirement that RTM be performed only by practice-employed clinical staff (not contractors) was delayed to January 1, 2029.1 Vendor-run RTM programs should be re-papered now.

Telehealth

Runway Through December 31, 2027

The Consolidated Appropriations Act, 2026 (signed February 3, 2026) extended Medicare telehealth flexibilities — including PT, OT, and SLP eligibility as distant-site practitioners and the home as an originating site — through December 31, 2027.12 Revenue that depends on telehealth beyond that date is a disclosed risk, not a run-rate.

Diligence Reality

Buyers Audit RTM Logs Against Claims

As covered in Mihama's compliance white paper, buyers reconcile RTM software logs (data days, interactive communication time) to the billing ledger. Under the 2027 rules, they will also look for the initiating visit and established-patient status. Unsupported RTM revenue is stripped from EBITDA entirely.

Action Plan
Eight Moves to Make Before January 1, 2027
1
Re-Price Your Top 15 CPT Codes

Use final 2027 RVUs and your locality GPCIs; weight by actual volume. Know your true Medicare rate change to the tenth of a percent.

2
Map Medicare Advantage Contract Language

Identify which MA and commercial contracts are pegged to a percentage of the Medicare fee schedule — the 2027 cut may flow through automatically.

3
Reprioritize Commercial Renegotiations

Every commercial rate improvement is a pro forma EBITDA add-back at sale. Time renegotiations so the new rates are in force before you go to market.

4
Audit Untimed-Code Dependence

Practices leaning on untimed modalities face the efficiency adjustment and weaker clinical defensibility. Shift toward skilled, timed intervention.

5
Choose Your MVP Path Now

Select 2027 measures with the new Core Measure requirement in mind. A 75-point score is the floor; below it, you are paying a penalty in 2029.

6
Build an Outcomes Data Asset

Collect validated PROMs consistently. They support MVP scoring, payer negotiations, hospital partnerships, and value-based models.

7
Re-Paper RTM Workflows

Document established-patient status, the initiating visit, data days, and interactive time. Plan for the 2029 in-house staffing requirement.

8
Quantify Telehealth Exposure

Isolate Medicare telehealth revenue and present it separately in your financials so buyers do not haircut your entire run-rate for a 2027 cliff.

Model the Reset Before a Buyer Does

Know Exactly How 2027 Changes Your Value

Mihama models your practice's code mix, payer mix, and Medicare exposure against the final 2027 rule — and shows you how buyers will underwrite it. Confidential, no retainer, paid only at close.

Speak With an Advisor

347-878-2941
Confidential consultation, no retainer required

Email Us

info@mihamainc.com
We respond within one business day

Learn More

www.mihamainc.com
Resources, white papers & transaction experience

Sources & Notes
  1. CMS, "Calendar Year (CY) 2027 Medicare Physician Fee Schedule Final Rule" (fact sheet), Nov. 4, 2026. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-final-rule
  2. CMS, "CMS Finalizes CY 2027 Physician Fee Schedule" (press release), Nov. 4, 2026. https://www.cms.gov/newsroom/press-releases/cms-finalizes-cy-2027-physician-fee-schedule-shift-sick-care-healthcare-curb-waste
  3. CMS, "Calendar Year (CY) 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F)" (fact sheet), Oct. 31, 2025. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule-cms-1832-f
  4. APTA, "CMS Finalizes Fee Schedule Pay Bump for the First Time in 5 Years," Nov. 18, 2025. https://www.apta.org/article/2025/11/18/cms-finalizes-fee-schedule-pay-bump-for-the-first-time-in-5-years
  5. Holland & Knight, "CMS Releases CY 2026 Medicare Physician Fee Schedule Final Rule," Nov. 12, 2025. https://www.hklaw.com/en/insights/publications/2025/11/cms-releases-cy-2026-medicare-physician-fee-schedule-final-rule
  6. Holland & Knight, "CMS Issues CY 2027 Medicare Physician Fee Schedule Proposed Rule," July 20, 2026. https://www.hklaw.com/en/insights/publications/2026/07/cms-issues-cy-2027-medicare-physician-fee-schedule-proposed-rule
  7. APTA, "APTA Analysis Reveals Greater Long-Term Payment Gains in Medicare Proposal," Sept. 1, 2026. https://www.apta.org/article/2026/09/01/apta-analysis-reveals-greater-long-term-payment-gains-in-medicare-proposal
  8. CMS, Transmittal R13437CP, "2026 Annual Update of Per-Beneficiary Threshold Amounts," Oct. 30, 2025; https://www.cms.gov/files/document/r13437cp.pdf WebPT, "The 2027 Proposed Rule Is Out" (proposed CY 2027 KX threshold of $2,540). https://www.webpt.com/blog/the-2027-proposed-rule-is-out-heres-what-you-need-to-know
  9. SPRY, "Medicare Conversion Factor and GPCI Changes" (citing AMA conversion factor history). https://www.sprypt.com/blog/medicare-conversion-factor-and-gpci-changes
  10. APTA, "Merit-based Incentive Payment System" (practice resource, PDF). https://www.apta.org/siteassets/pdfs/payment/merit-based-incentive-payment-system.pdf
  11. CMS, "Therapy Services" (CY 2026 therapy code list updates, including RTM codes designated sometimes therapy). https://www.cms.gov/medicare/coding-billing/therapy-services
  12. Baker Donelson, "Medicare Telehealth Waivers Extended for Several More Years" (Consolidated Appropriations Act, 2026). https://www.bakerdonelson.com/medicare-telehealth-waivers-extended-for-several-more-years
  13. AOTA, "CY 2027 MPFS Proposed Rule: Key MIPS and Quality Reporting Changes for Occupational Therapy," 2026. https://www.aota.org/advocacy/advocacy-news/2026/cy-2027-mpfs-proposed-rule-key-mips-and-quality-reporting-changes-for-occupational-therapy
  14. SPRY, "CMS Final Rule 2026: 7 Critical Changes for Physical Therapists" (efficiency adjustment code list; Medicare G0283 vs. 97014). https://www.sprypt.com/blog/2026-cms-final-rule-7-critical-changes-for-pt
  15. APTA, "Proposed 2027 Medicare Physician Fee Schedule: What PTs Need to Know, Part 1," July 24, 2026. https://www.apta.org/article/2026/07/24/proposed-2027-medicare-physician-fee-schedule-what-pts-need-to-know-part-1

Final-rule figures are from CMS materials released November 4, 2026. Code-level RVUs, the final CY 2027 KX threshold, and specialty impact tables should be confirmed against the final rule addenda and CMS transmittals as they are published. Valuation examples are illustrative.