In July, CMS proposed the biggest shift to physician payment in years, and most practices in Florida haven't read past the headline. Here is what the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) actually does.
The base rate drops
The base pay rate falls in 2027, to $32.84 for most physicians. The 2026 fix expired and wasn't renewed. After inflation, Medicare physician pay is down 33% since 2001.
The multi-TIN loophole closes
Today, qualifying participant (QP) status in a value-based model earns the bonus rate at every practice a physician bills under. The proposal limits it to the one actually in the program. CMS estimates this claws back $2.38 billion, and it lands squarely on multi-TIN MSO and IPA structures.
A real raise for physicians in ACOs
On the other side of the ledger, the rule proposes a 32% increase on office visits for physicians inside an ACO, billable for all their patients, not only assigned ones. CMS is turning "join an ACO" into a per-visit cash decision rather than a someday-savings promise.
Traditional MIPS ends after 2028. Remote monitoring can no longer be run by contractors. Small physician-led ACOs get a better deal.
Why it matters in Florida
Florida is the second-largest Medicare market in the country, with about 5.2 million beneficiaries and roughly 57% in Medicare Advantage. Most of this rule governs traditional Medicare, so the opportunity sits in a pool that many MA-focused groups here have overlooked.
This rule doesn't just cut pay. It re-prices participation. It penalizes arbitrage and rewards real accountable care.
Figures are from the proposed rule as published in July 2026. CMS typically issues the final rule in the fall; check the final rule for any changes.
Originally shared on LinkedIn. Follow along there for weekly notes on value-based care, primary care and policy.