Downcoded

8% of Practitioners, 18% of the RVUs

CMS quietly published a spreadsheet showing how the CY 2027 fee schedule lands on individual practitioners rather than on specialty averages. Count practitioners and 8.3% take a cut deeper than 2%. Count RVUs and it is 17.6%, roughly $15 billion of the fee schedule. The specialty average everyone quotes is published as five TIFF images.


CMS explains the specialty impact table in the CY 2027 physician fee schedule column by column, and then tells you it does not describe anybody.

Table D-B5 is the one every trade summary runs: one percent change per specialty, radiology up, dermatology down, print it and move on. Here is what the agency says about it in the regulatory impact analysis.

"They are averages and may not necessarily represent what is happening to the particular services furnished by a single practitioner within any given specialty."

So CMS built something else. "To illustrate how impacts can vary within specialties, we created a PUF that models the expected percentage change in total RVUs per practitioner."

The new file is a spreadsheet covering 1.44 million practitioners and 2.65 billion RVUs.

Table D-B5, the average everyone quotes, is published in the Federal Register as five TIFF images.

The Headline Read Is Boring

Take the file at face value and CY 2027 looks calm. 30.4% of practitioners land inside a single point of zero, 46.7% inside two points, 71.1% inside five.

Only 8.3% take a cut deeper than 2%, which is about 119,600 clinicians out of 1.44 million.

That is the number a specialty society will put in a comment letter, and it is the wrong one.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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