What Are the Proposed 2027 Medicare Changes for Gastroenterology?
As of July 2026, the CMS CY 2027 Physician Fee Schedule proposed rule introduces payment reductions that directly affect gastroenterology practices. The proposed changes include a 3 percent decrease in physician payments for GI endoscopy services performed in ambulatory surgery centers and hospital outpatient departments, a 50 percent payment cut when a same-day E/M visit is billed alongside a procedure by the same physician, and a conversion factor decrease of 1 to 1.7 percent as the temporary 2026 payment increase expires. The ACG, AGA, and ASGE have all issued alerts urging GI providers to respond before the September 14, 2026 comment deadline.
Endoscopy revenue at risk: Physician payments for GI endoscopy in ASCs and HOPDs are projected to drop by 3 percent, with some high-volume codes seeing cuts as high as 8 percent.
Same-day billing penalized: If finalized, the highest-paid service on a given day would be reimbursed in full while every additional service billed that day would be paid at 50 percent of its normal rate.
Comment window closing: The proposed rule is accepting public comments through September 14, 2026, and the final rule is expected later this fall.
What CMS Proposed for GI in 2027
On July 14, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule, designated CMS-1848-P. The rule proposes payment policy changes for Medicare Part B services effective January 1, 2027. For gastroenterology, the proposed rule carries three distinct financial hits.
First, the conversion factor is dropping. The proposed 2027 conversion factor is $33.17 for physicians in a qualifying Advanced Alternative Payment Model and $32.84 for those who are not. Compared to 2026 rates, that represents a cut of 1 percent and 1.7 percent, respectively. The decrease stems primarily from the expiration of the temporary 2.5 percent payment increase Congress enacted for 2026 under the Working Families Tax Cut legislation.
Second, GI endoscopy payments are taking a targeted hit. According to the ACG’s July 17, 2026 member alert, physician payments for GI endoscopy services performed in ambulatory surgery centers and hospital outpatient departments are expected to decrease by 3 percent. Some individual high-volume GI codes could see reductions as high as 8 percent under the proposed ASC and OPPS payment schedules.
Third, CMS is proposing a structural change to same-day billing. Under the proposal, when a physician bills a separately identifiable E/M visit on the same day as a procedure with a 0-, 10-, or 90-day global period, the highest-paid service would be paid at 100 percent and every additional service would be paid at only 50 percent. For gastroenterologists who routinely see a patient in the office and perform a procedure the same day, this change would directly reduce reimbursement on a significant portion of their Medicare claims.
The comment period closes September 14, 2026.
Who Do These Payment Cuts Apply To?
The proposed payment changes affect every gastroenterology practice and billing entity that submits Medicare claims for endoscopy services or same-day E/M visits with procedures. The scope includes solo gastroenterologists and independent GI groups, multi-physician practices operating ambulatory endoscopy centers, hepatology practices billing infusion services, and any billing company or revenue cycle management partner handling GI claims.
The 3 percent endoscopy cut applies specifically to services performed in ASCs and hospital outpatient departments. Office-based endoscopy practices may see different effects depending on how CMS finalizes the practice expense methodology. The same-day E/M reduction applies across all settings and would affect any gastroenterologist who bills a separately identifiable office visit alongside a colonoscopy, EGD, or other procedure on the same calendar day. In our experience matching providers with billing partners through Gastroenterology Billing, the practices most at risk are mid-size GI groups that perform high volumes of screening and diagnostic colonoscopies with a same-day consultation or follow-up visit billed under modifier 25.
Medicaid and commercial payers often benchmark their rates against the Medicare PFS, so the downstream effect on private payer contracts is likely, though the timeline will vary by payer.
Why CMS Is Targeting Same-Day Billing
CMS has framed the same-day E/M payment reduction as an effort to eliminate what it views as duplicative payments. The agency’s position is that when a physician performs both an E/M visit and a procedure on the same day, some of the physician work involved in the visit is already captured in the procedure’s relative value units. CMS proposed a similar policy in the CY 2019 PFS proposed rule but did not finalize it at that time.
The 2027 version revives and expands that concept. Under the proposal, the most expensive service performed on a given day would be paid in full, while all other services, whether additional procedures or E/M visits, would be reimbursed at 50 percent of their scheduled rate. CMS has stated that this approach would address what it considers overvaluation in the current system.
One question we hear constantly from practice managers is whether their billing team can actually identify which claims will be affected. For gastroenterology specifically, the impact is concentrated in a predictable pattern: a patient arrives for a scheduled colonoscopy or EGD, the gastroenterologist also performs a separately identifiable evaluation documented with modifier 25, and both the procedure and the E/M visit are billed on the same claim. That workflow describes a substantial percentage of GI procedure days. The proposed rule would reduce the lower-valued service on every one of those claims by half.
How Much Revenue Could Your GI Practice Lose?
The revenue impact depends on your practice’s volume of same-day E/M and procedure claims, the setting where you perform endoscopy, and your payer mix. Here is a simplified example of how the proposed changes stack for a facility-based GI practice:
| Revenue Component | 2026 (Current) | 2027 (Proposed) |
| Conversion factor (non-APM) | $33.40 | $32.84 (1.7% decrease) |
| ASC/HOPD endoscopy payment | Current rates | 3% decrease (up to 8% on select codes) |
| Same-day E/M with procedure | Paid at 100% with modifier 25 | Lower-valued service paid at 50% |
| Colonoscopy with snare polypectomy (45385) | 2026 rate | $18.00 less per procedure (ACG estimate) |
For a GI practice performing 20 colonoscopies per week in an ASC with a same-day E/M visit on most of those encounters, the combination of the 3 percent endoscopy cut and the 50 percent same-day E/M reduction can translate to tens of thousands of dollars in annual Medicare revenue lost. Multiply that across a multi-physician group, and the financial pressure is substantial. These numbers are based on the proposed rule and could change in the final version, but the ACG’s preliminary analysis confirms the directional impact is significant.
What to Do Before September 14
The September 14, 2026 comment deadline is the most immediate action date. Regardless of whether the final rule changes, the financial modeling and billing review you do now protects your practice no matter what CMS decides. Here is the preparation checklist:
1. Quantify your same-day E/M and procedure volume. Pull a report of every claim from the past 12 months where your practice billed an E/M visit with modifier 25 on the same day as an endoscopy or other procedure. This is your exposure number.
2. Model the revenue impact at 50 percent. Apply a 50 percent reduction to the lower-valued service on every same-day claim in your report. The resulting number is your maximum annual Medicare revenue at risk under this proposal.
3. Review your documentation for modifier 25 compliance. CMS is clearly signaling that same-day E/M billing is under scrutiny. Ensure every same-day visit in your practice meets the separately identifiable standard and that your documentation supports the medical necessity of a distinct E/M service.
4. Contact your top payers. Confirm whether any commercial or Medicaid payers have indicated they will mirror the proposed Medicare policy. Some payers adopt PFS changes directly; others wait.
5. Submit a public comment. The comment period closes September 14, 2026. The ACG, AGA, and ASGE are all organizing advocacy responses. A similar proposal in 2019 was not finalized after significant pushback.
6. Evaluate your billing partner’s readiness. If you outsource billing, confirm that your billing company understands the proposed changes, can model the revenue impact for your practice, and has a plan to adjust workflows if the rule is finalized.
Common GI Billing Mistakes This Change Will Expose
The most common issue we see providers run into is that their billing team treats every same-day E/M visit as automatically justified by modifier 25 without verifying that the documentation actually supports a separately identifiable service. Under the current system, an underdocumented same-day visit still gets paid at full rate if it clears the claim edit. Under the proposed system, it gets paid at 50 percent regardless of documentation quality, and if it also triggers an audit, the practice faces both reduced payment and a potential recoupment.
Across the billing companies we vet, a recurring pattern in GI practices is that screening colonoscopies are miscoded as diagnostic when a polyp is found during the procedure, but the correct preventive modifier (modifier 33 or modifier PT) is not applied. The patient ends up with an unexpected balance, and the practice ends up defending the claim. When the same-day E/M reduction layers on top of these existing modifier errors, the revenue leak compounds. The $18.00 per-procedure cut on a colonoscopy with snare polypectomy (CPT 45385) plus a 50 percent reduction on the same-day E/M visit plus an incorrect modifier assignment on the screening-to-diagnostic conversion creates a three-layer revenue loss that most in-house billing teams do not model until it is already in their accounts receivable.
Practices that already struggle with the multiple endoscopy payment reduction on multi-procedure sessions will find the new same-day rules even harder to manage. The calculation of which service is highest-paid when multiple procedures and an E/M visit occur on the same day adds another variable to an already complex billing sequence.
In-House Billing vs. a GI Billing Partner
Providers often come to us after a reimbursement change has already reduced their revenue, not before. The 2027 proposed rule gives GI practices an opportunity to evaluate billing operations before the cuts take effect rather than reacting after the fact.
A billing company with direct gastroenterology experience already understands the same-day E/M and endoscopy billing workflow, manages modifier 25 documentation compliance across multiple payers, handles the screening-versus-diagnostic colonoscopy distinction correctly, and applies the multiple endoscopy payment reduction accurately on multi-procedure sessions. These are the exact areas where the proposed 2027 changes will create the most financial exposure.
If your current billing setup cannot model the revenue impact of the proposed same-day rule, cannot tell you how many of your claims would be affected, or cannot distinguish between screening and diagnostic coding on a colonoscopy that converts mid-procedure, those are signals that your billing operation is not positioned for what 2027 may bring. Gastroenterology Billing connects GI practices with billing companies that specialize in exactly these scenarios, not generalists who will discover the new rules the same day your claims start getting reduced.
The proposed 2027 payment changes target the exact billing scenarios that define gastroenterology: same-day E/M visits with endoscopy, modifier compliance, and multi-procedure sessions. If your billing team cannot model the impact or adjust workflows before the final rule, now is the time to connect with a GI billing company that can.
Frequently Asked Questions
When do the proposed 2027 GI payment changes take effect?
The proposed changes are part of the CY 2027 Medicare Physician Fee Schedule proposed rule and would take effect January 1, 2027, if finalized. CMS is accepting public comments through September 14, 2026, and the final rule is expected later this fall. The specific provisions, including the same-day E/M reduction, could be modified or removed in the final version.
How much will GI endoscopy payments decrease in 2027?
According to the ACG’s July 2026 member alert, physician payments for GI endoscopy services performed in ASCs and HOPDs are expected to decrease by 3 percent. Individual codes may see higher reductions. The ACG estimates that colonoscopy with snare polypectomy (CPT 45385) would be reimbursed $18.00 less per procedure than current rates for facility-based services.
Does the same-day E/M cut apply to office-based endoscopy?
Yes. The proposed 50 percent reduction applies when a separately identifiable E/M visit is billed on the same day as a procedure with a global period, regardless of the place of service. Office-based, ASC-based, and HOPD-based GI practices would all be affected if they routinely bill same-day E/M visits with endoscopy procedures.
Will commercial payers follow the Medicare same-day E/M rule?
It depends on the payer. Many commercial and Medicaid payers benchmark their payment policies to the Medicare PFS, but the timing and extent vary. Some payers adopt Medicare changes directly; others maintain their own same-day billing policies. GI practices should contact their top payers to confirm whether they plan to mirror this proposal if it is finalized.
Is this the same proposal CMS made in 2019?
CMS proposed a similar same-day E/M payment reduction in the CY 2019 PFS proposed rule but did not finalize it after receiving significant pushback from provider organizations. The 2027 proposal revives the concept in a slightly different form. The ACG, AGA, and ASGE are again organizing advocacy responses, and the comment period closes September 14, 2026.
What are the new endoscopic submucosal dissection codes for 2027?
CMS proposes work RVUs of 15.00 for upper gastrointestinal ESD and 16.38 for lower gastrointestinal ESD. These would be the highest physician work values in GI endoscopy when they take effect in 2027. Practices performing ESD should ensure their billing partner can support the new code set and documentation requirements.
Next Steps
Review the ACG’s full summary of the proposed 2027 PFS and OPPS/ASC payment changes at gi.org before the September 14 comment deadline.
Pull your same-day E/M and endoscopy billing volume for the past 12 months and model the revenue impact of a 50 percent reduction on the lower-valued service.
If your billing team cannot quantify the impact or adjust documentation and coding workflows in time, we can connect you with a GI-specialized billing company in as little as 30 minutes.
The proposed 2027 Medicare changes represent one of the largest targeted payment reductions for gastroenterology in years. Whether you need a billing partner who already understands GI-specific coding and modifier rules or want to compare your current company’s readiness, Gastroenterology Billing matches you with vetted GI billing experts at no cost.
