Endocrine Society Pushes Back on Medicare Payment Changes for 2027
The Endocrine Society has pressed the Centers for Medicare and Medicaid Services on the 2027 Medicare Physician Fee Schedule proposed rule, arguing that the payment update, as written, would continue to strain physician reimbursement even as endocrine-specific services receive a modest boost. The society submitted comments on September 11, days after CMS published a rule that governs annual payment policies and rates for Part B services billed under the Medicare Physician Fee Schedule.
One figure drives the dispute. If finalized, the rule would produce a 2.5% increase for the endocrinology specialty while also cutting the overall conversion factor by 2.5% for all physicians. In practical terms, the specialty-specific gain does not erase the broader squeeze on physician payments, particularly in a system where the conversion factor determines the baseline value applied across Medicare billing.
Congressional action sits at the center of the society’s response. The Endocrine Society is urging lawmakers to adopt an annual inflationary update to the Medicare Physician Fee Schedule tied to the Medicare Economic Index, a change the group says would override the rule and better match reimbursement with rising practice costs. In a field where care is often longitudinal, interpretation-heavy, and procedure-linked, reimbursement policy can shape which services remain sustainable in ordinary outpatient practice.
Fine Needle Aspiration Equipment Gets a Rare Payment-Rules Win
Among the provisions drawing support is CMS’s proposal to create a new practice expense equipment item for Fine Needle Aspiration, designated ER130 and described as “Fine Needle Aspiration portable ultrasound.” Endocrinologists frequently use FNA in the evaluation of thyroid nodules and other targeted lesions, and the society backed the update to the practice expense inputs supporting those services. The society also worked with other medical organizations on the change through the CPT and RUC process.
This is not a trivial administrative adjustment. Practice expense inputs influence whether a procedure reflects the real-world cost of delivering care, including equipment and operational demands that are easy to miss when billing rules lag behind clinical practice. Portable ultrasound has become central to many FNA workflows, and payment rules that recognize that equipment can make office-based endocrine procedures more viable.
The society framed the proposal as a clear win for endocrinologists who perform FNAs. For a specialty that relies on outpatient diagnostic procedures to distinguish benign from malignant disease, reimbursement accuracy affects more than accounting; it shapes access, scheduling, and the feasibility of keeping procedures close to the clinic rather than shifting them into higher-cost settings.
G2211 Replacement Draws Concern Over Work RVUs
CMS has also proposed deleting the recently created G2211 complex care code and replacing it with a new modifier, MOD1. When appended to an appropriate evaluation and management code, the modifier would increase payment by 16% of the value of the reported E/M CPT code. On paper, that sounds like an administrative substitute for complex care recognition. In actual practice, the society says the change threatens a different currency altogether: work RVUs.
That issue lands hardest for endocrinologists working in larger hospital systems and universities. The society warned that the proposal would reduce work RVUs for physicians in those settings, a result that could ripple through compensation models, productivity benchmarks, and departmental budgeting. In academic and integrated-care environments, RVUs are not abstract bookkeeping entries. They are often the mechanism by which clinical effort is translated into salary support and institutional credit.
The Endocrine Society urged CMS not to finalize the proposal and to keep the G2211 code in place. Its concern is straightforward: replacing a code with a modifier may preserve one slice of payment while eroding another measure of physician work, particularly in settings where documentation, care coordination, and longitudinal disease management are already labor-intensive.
Modifier 25 Proposal Raises Separate Payment Concerns
The society also asked CMS not to finalize a proposal that would reduce payment when a Modifier 25 is used under certain circumstances during billing for an E/M visit. Modifier policy often appears technical, but it can determine whether physicians are paid appropriately when separate, identifiable services occur on the same day as evaluation and management care.
For endocrinology, where a single encounter may involve counseling, medication adjustment, procedure planning, and diagnostic decision-making, changes to modifier policy can have outsized consequences. A rule that narrows payment in these circumstances may not change the clinical work itself, but it can alter whether that work is fully recognized by Medicare.
The society’s position reflects a familiar tension in physician payment: small coding adjustments can accumulate into major practice effects when applied across high-volume outpatient care. Even modest reductions in recognized payment may influence whether practices can maintain staffing, preserve procedure capacity, or continue absorbing the overhead tied to complex chronic disease management.
Final Rule Expected in Early November
The Endocrine Society staff worked with the Clinical Affairs Core Committee to draft the comments submitted to CMS. The collaboration suggests the response was not only policy-driven but also grounded in day-to-day clinical operations, especially for endocrinologists whose work spans office visits, diagnostic procedures, and chronic care follow-up.
The final rule is expected by early November at the latest. Until then, the central question is not whether Medicare payment policy matters; it is how much of endocrine care CMS will recognize when the 2027 rule is locked in.
The society’s letter places several pressure points in front of regulators at once: the need for an inflation-linked conversion factor, the cost realism of FNA equipment, the preservation of G2211, and the protection of Modifier 25 payment in appropriate E/M billing scenarios. Each issue touches the same underlying problem. Medicare payment policy can either track the work endocrinologists actually do, or drift further away from it.