CMS Wants to Reduce Administrative Burden. Here’s What Practices Will Actually Have to Change

Every year CMS releases the Physician Fee Schedule proposed rule, and every year the press release says roughly the same thing: less burden, more value, better outcomes. The CY 2027 version, released July 14, 2026, uses almost exactly that language — CMS says its goal is “to deliver better outcomes for patients by appropriately incentivizing providers, improving quality measurement, and reducing administrative burden.”

Practice administrators who have sat through a few of these cycles know the pattern by now: the framing says simplification, the fine print says migration. This year is no exception. Buried inside a genuinely burden-reducing package are several structural changes that will require new reporting workflows, EHR configuration changes, and in some cases entirely new group-reporting structures before they take effect. Comments on the proposed rule are open through September 14, 2026, and a final rule is expected later this year — which means practices have a real, if narrow, window to prepare and to weigh in.

Here’s what’s actually in it, separated by what will save you work and what will cost you work.

The Payment Number First, Because It Matters

The proposed CY 2027 conversion factor is $33.1693 for clinicians in qualifying Advanced Alternative Payment Models, and $32.8409 for everyone else — decreases of 1.19% and 1.68%, respectively, from the final CY 2026 rates. That’s a modest cut, not a dramatic one, but it’s a cut, and it lands at the same time CMS is asking practices to absorb new reporting infrastructure. Budget conversations at the practice level should treat these as connected line items, not separate ones.

The Part that Actually Reduces Burden

CMS’s deregulatory instinct shows up most clearly in three places.

Electronic prior authorization reporting becomes a bonus, not a requirement. For the 2027 MIPS performance year, CMS proposes making the electronic prior authorization measure optional rather than mandatory, with successful reporting earning 10 Promoting Interoperability bonus points. For practices that have already invested in electronic prior authorization workflows, this is a straightforward win: keep doing what you’re doing and collect the points. For practices that haven’t built the infrastructure yet, it removes a looming MIPS reporting requirement without removing the incentive to eventually get there. Importantly, this does not mean electronic prior authorization itself is becoming optional across the healthcare system: CMS’s separate interoperability rules still require certain impacted payers to implement Prior Authorization APIs beginning January 1, 2027.

Accountable Care Organizations get real relief on certified technology requirements. CMS proposes allowing ACOs to satisfy the Shared Savings Program’s CEHRT use requirement through one of three activities instead of requiring them to report all MIPS Promoting Interoperability measures. The proposed pathways include reporting at least one ACO-reported APP Plus measure through the eCQM or Medicare eCQM collection type, along with other specified CEHRT-use activities. CMS is also proposing to keep the MIPS Clinical Quality Measures collection type available for Shared Savings Program ACOs reporting the APP Plus measure set beyond 2026, specifically to avoid forcing ACOs into an unplanned mid-stream switch in reporting methodology.

Beneficiary notification gets simpler. ACOs currently have to provide certain Original Medicare beneficiaries with a standardized written notice before or at the beneficiary’s first primary care service visit during the first performance year in which that beneficiary receives a primary care service from an ACO participant. CMS proposes removing that visit-based trigger and instead requiring the ACO or ACO participant to provide the standardized notice at least once during an agreement period, generally by May 30 unless CMS specifies a later date.

Remote monitoring codes may consolidate. CMS is soliciting comment on replacing the current 17 RPM and RTM CPT codes with four new HCPCS G-codes — GRPM1/GRPM2 for remote physiologic monitoring and GRTM1/GRTM2 for remote therapeutic monitoring. If finalized, this could meaningfully simplify billing logic for practices running active RPM/RTM programs, although it is currently a request for comment rather than a finalized policy, so the structure could still change.

The Part that Will Require Actual Work

This is where practice administrators, billing managers, and EHR managers should be paying closest attention, because several of these proposals sound like housekeeping and function like migrations.

MIPS is being phased out — starting with the reporting structure practices use today. CMS proposes giving MIPS eligible clinicians through the end of 2028 to transition to MIPS Value Pathways, with MVPs becoming the sole MIPS reporting framework beginning with the 2029 performance year for clinicians outside MIPS APMs that report through the APM Performance Pathway. The operational challenge is not simply learning a new reporting interface. MVP reporting is built around specialty-focused subgroups, which means organizations that currently manage quality reporting at the group level may need to rethink how clinicians are organized, measures are selected, and performance data are governed. For a multispecialty practice, 2027 is a sensible year to start that subgroup design work rather than waiting until the transition becomes mandatory.

The “outcome measure” requirement is being replaced by a “core measure” requirement — with a catch. Currently, MIPS requires reporting at least one outcome or high-priority measure. CMS proposes eliminating the high-priority designation and instead requiring at least one core measure considered fundamental to each clinician’s specialty and patient population. If a clinician has no applicable core measure, the proposal provides for an attestation during submission. CMS also proposes changing how core measures are scored: they would not be subject to the existing 7-point cap. Separately, a measure that has been topped out for two or more consecutive years would be scored on a 1–10 scale against a defined benchmark, changing the scoring math practices use to plan their MIPS strategy from year to year.

Practice expense calculation methodology is changing under the hood. CMS is continuing its multi-year effort to change how practice expense data are collected and used in calculating practice expense RVUs. The agency argues that the current approach relies on specialty-specific data that can be difficult and costly to collect and may suffer from low response rates and inconsistent methodologies. The transition is intended to use more objective and routinely updated cost information — but for practices, the practical issue is that changes in the methodology can change how practice expense RVUs are assigned, which affects reimbursement modeling regardless of how much reporting burden the new approach removes.

Global surgical period data collection is being paused, not eliminated. CMS proposes to pause the MACRA-mandated data collection on post-operative visits during global periods, citing several years of data showing that many post-operative visits included in global surgical payment bundles are not occurring even though providers are still being paid for them under current policy. CMS also says the current collection requirements may be creating undue burden for providers. The agency is continuing to solicit comments on other data sources and potential future approaches to more accurately value global surgical services. For practices with significant surgical volume, that makes this more than a temporary reporting reprieve: it is a signal that global-period valuation remains under active review.

Remote monitoring rules are tightening even as the codes may simplify. Alongside the potential G-code consolidation, CMS proposes four substantive RPM/RTM changes: lower valuations for several existing codes, a requirement that Medicare-payable RPM/RTM services be furnished by clinical staff employed by the billing practice rather than contractors, a new established-patient requirement for RTM, and a separately reportable initiating visit associated with the onset of RPM/RTM services. Practices that currently rely on a third-party vendor’s clinical staff to perform billable monitoring work should treat this as the proposal most likely to force an operational change if finalized. The issue is not necessarily whether a practice can continue buying devices, software, or other support from a vendor; it is whether the clinical staff furnishing the billable services are employed by the billing practice.

Advanced APM qualification is moving to a narrower unit of measurement. CMS proposes changing the methodology used to determine Qualifying APM Participant status so that the relevant TIN/NPI combination is used rather than relying solely on the individual NPI. Under the proposal, the associated APM incentive payment and conversion-factor treatment would apply to services billed through a clinician’s APM-participating TIN. CMS estimates that the proposed change would prevent approximately $2.38 billion in windfall APM incentive payments over the next decade to clinicians who do not participate in APMs. For any physician who bills through multiple TINs — a common setup for those splitting time between a hospital-employed role and an independent practice, for instance — this is worth modeling now, before the proposal is finalized.

What Industry Groups Are Already Pushing Back On

The American Medical Group Association (AMGA) has flagged one issue in particular: the mandatory Ambulatory Specialty Model (ASM) remains mandatory and two-sided even in this rule, and AMGA argues that it creates overlapping accountability and conflicting incentives for specialists already participating in the Medicare Shared Savings Program. Its formal request to CMS is to preserve entity-level Qualifying Participant determinations, reject mandatory specialty payment models in favor of voluntary participation, and align quality measurement across the ASM, MIPS, and MSSP so specialists are not reporting duplicate data through parallel systems. Whether CMS incorporates that feedback before the final rule is exactly the kind of detail the September comment period exists to influence — and exactly why comment periods on rules like this are worth a practice’s time even when the deadline feels administrative rather than urgent.

What to Actually Do Before November

If you’re a multispecialty group: start mapping which clinicians would form which MVP subgroups. This is a governance conversation as much as a technical one, and it takes longer than people expect.

If you outsource RPM/RTM monitoring to a third-party vendor: get ahead of the proposed employment requirement now. Ask your vendor directly who performs the clinical monitoring work and what their contingency plan is if CMS finalizes the proposal. Build your own fallback before you need one.

If your practice bills through more than one TIN: model the APM qualification impact under the proposed TIN/NPI framework before assuming your future incentive payment or conversion-factor treatment will look like today’s.

If you’re an ACO: the CEHRT pathway flexibility and beneficiary notification simplification are genuine wins — but confirm with your EHR vendor now which of the proposed CEHRT pathways your current system can support, so you’re not scrambling to choose one in Q4.

Everyone: the comment deadline is September 14, 2026. Specialty societies and industry groups are already submitting detailed responses on measure sets, valuation methodology, and the ASM’s mandatory structure. A short practice-level comment, filed directly or through your specialty society, costs almost nothing and is one of the few points in this entire cycle where a practice administrator’s input can still influence the outcome before the rule is finalized.

None of this is the dramatic AI-denial-machine story making headlines elsewhere in health policy this year. It’s slower, more procedural, and — for the people who actually have to configure the EHR, retrain the billing staff, and file the MIPS submission — considerably more consequential.

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