Still proposed. Comments closed (OPPS August 31, PFS September 14); the final rules are expected in early November 2026, and this page changes when they land. Read the PFS proposal →
CY2027 proposed rules · read from the primary
CY2027 is a scissors,
not a cut.
CMS proposes to reduce the work RVUs on hip and knee replacement roughly 20 percent — largely because the case already moved outpatient. The value does not disappear. It reappears on the facility line at +2.4 percent.
Whether you keep it depends on whether you own the building.
−20%
work RVUs, 27130 / 27447
Proposed cut to the work RVUs on hip and knee replacement — roughly 3× the ortho specialty average. In the PFS rule, not this one.
CMS-1848-P →
+2.4%
OPPS and ASC facility rates
The same proposed update on both facility systems, so ASC total payments rise with it.
CMS-1850-P →
50%
same-day visit + procedure
Proposed: when a modifier-25 visit and a 0-, 10- or 90-day global procedure share a day, the lower-valued of the two is paid at half.
CMS-1848-P →
Jan 1, 2029
inpatient-only list is gone
1,438 services remain today. CY2027 proposes removing 637 of them; CY2028 takes the rest.
CMS OPPS notices →
The mechanism nobody prices in
The professional cut and the facility raise are not two unrelated line items. They are one movement, and it runs in a specific order.
01
The case leaves the inpatient-only list
Total joints came off years ago — knee in 2018, hip in 2020. The procedure migrates to the hospital outpatient department or the ASC.
02
A site-of-service screen flags the professional code
Once the case is routinely done outpatient, the valuation of the professional work gets re-examined against the new setting.
03
The work RVUs come down
CMS accepted the RUC recommendation to cut work RVUs on 27130 and 27447 roughly 20%. AAHKS and AAOS have filed against it.
04
The facility line goes up 2.4%
The value did not evaporate. It moved across the bill. Whoever owns the facility collects it; a surgeon with no ownership simply absorbs the professional cut.
And it is recurring, not a one-time event.
The screen marches down the migration list. Hip and knee are simply the codes that migrated first and carry the most volume. Shoulder and spine sit behind them on the same path — the CY2026 rule already moved lumbar fusion (22630, 22633) onto the ASC-covered list. Anything that leaves the inpatient-only list eventually gets its professional valuation re-examined in the setting it moved to.
Same day, half paid
The second cut in the physician rule lands in clinic, not the OR. The classic orthopedic visit is an evaluation and an injection or fracture care in the same room on the same day.
What CMS proposes
A modifier-25 visit billed with a procedure that carries a 0-, 10- or 90-day global period: the higher-valued service is paid in full, the lower-valued one at 50 percent. Codes with no global period (XXX) are left out.
CMS-1848-P →
Who feels it
Independent groups first, because a professional-fee cut has nothing to offset it. One New Mexico group put the change near 3 percent of its revenue; a Maryland group's president called it possibly “the death knell of a lot of private practices.”
Becker's Spine, Oct 2026 →
What the record has to carry
Nothing about modifier 25 itself changes: the visit still has to be significant and separately identifiable, in the note. Under a 50 percent rule, every same-day pair is worth reading twice, and the record is what an auditor reads.
Read a note with Wonder Bill →
Some groups are weighing moving injections to a separate day to keep both services whole. That is a call for the practice and the patient, who makes the second trip. Status: proposed, not final. Why modifier 25 has practices on edge →
Model your own exposure
Every assumption is on screen and editable. This models the proposed rules at your own numbers — it is not a fee-schedule lookup, and it is not advice.
The cut applies to work RVUs, which are only part of the payment. Typically around 55% for major arthroplasty — check your own fee schedule.
Enter your work-RVU share, then model it. The output shows the effective cut to your professional payment and whether the facility-side increase reaches you, which is the part that changes with ownership.
Modeled from the proposed CY2027 rules, not a fee-schedule lookup. Both rules are proposed and may change before they are finalized. Your actual payment depends on your locality, your payer mix, the final conversion factor, and the final RVUs. Verify against your own schedule before you act on it.
CY2027 is not orthopedics’ year — and that is the point
The headline making the rounds is “618 codes added to the ASC list, 637 off inpatient-only.” Both numbers are real. Neither one is about your panel.
They are the same procedures
The rule proposes to add 618 procedures to the ASC covered list precisely because it proposes to remove them from inpatient-only. It is one migration counted twice, not two separate expansions.
Read the rule text →
Musculoskeletal is not on the list
The CY2027 removals come from eleven clinical families: auditory, digestive, endocrine, female genital, hemic and lymphatic, integumentary, male genital, maternity care and delivery, mediastinum and diaphragm, respiratory, and urinary. Ortho is in none of them.
ASC covered-list addenda →
Because you already went
Knee replacement came off inpatient-only in 2018, hip in 2020. Orthopedics is not waiting for this migration. It is the precedent everyone else is now following — and the professional revaluation is what came after.
OPPS rule history →
If someone tells you 618 new codes just opened up for your panel, they did not read the rule. What actually matters to an orthopedic practice in this document is the facility update, the pace of the inpatient-only phase-out — 1,438 services remain, about half proposed to go in CY2027, the rest in CY2028, the list eliminated entirely on January 1, 2029 — and what all of that implies for who owns the room your cases are done in.
Two forces you should price separately
PRICE — WORKING AGAINST YOU
The leverage gap no negotiation closes
On commercial contracts, hospital outpatient departments are paid roughly 278 percent of Medicare while independent ASCs get about 171 percent. RAND’s work attributes most of that variation to hospital market power, not quality. Under Medicare, the ASC conversion factor sits near 62 percent of the hospital outpatient rate. The +2.4 percent lands on a structurally lower base.
RAND price transparency research →
VOLUME — WORKING FOR YOU
The cases are being steered your way
In March 2026 the Department of Justice sued NewYork-Presbyterian in the Southern District of New York under Section 1 of the Sherman Act over contract terms that blocked insurers from steering patients to lower-cost sites including ASCs. Site-of-care steering is now a federal antitrust priority, and commercial payers have moved the same direction with site-of-service policies.
DOJ Antitrust Division →
Put together: hospitals keep the per-case price premium, but they are losing the volume. An independent ASC takes a lower price per case and a rising, payer-directed share of the cases. That makes this a volume argument, not a rate argument — which means your two real levers are cost per case and patient demand, not the contract you were never going to win.
Two things are still inside your control
You cannot vote the RVU back by yourself. These are the moves that remain before January 1.
AFTER THE FINAL RULE
Comment on the record
Both comment windows have closed (OPPS August 31, PFS September 14). What the final rules keep is answered next through the specialty societies and the following year's rule. A comment from a surgeon who does the case carries a different weight than one from a trade association.
Docket CMS-2026-2344 →
EVERY DAY BETWEEN NOW AND THEN
Capture what the current schedule already owes you
A proposed cut you cannot control is a bad reason to keep leaving money on a schedule you can. Wonder Bill reads an operative note and finds the codes that were supported and not billed.
Run a note through Wonder Bill →
BY SEPTEMBER 14, 2026
Have something specific to say in it
Every specialist value-based proposal on the table depends on a 60–90 day preoperative program that no code pays for. A comment naming the missing mechanism is more useful to the agency than one naming the grievance.
The optimization gap →
THE LONGER ARC
Where the episode economics go next
If the value keeps moving from the professional line to the facility and episode side, the practices that hold up are the ones that can carry an episode. See how the rest of the payment stack lines up.
SurgeonValue economics →
ONE RULE IN THIS CYCLE IS ALREADY FINAL
Everything above is proposed. CJR-X is not.
The work-RVU cut and the facility bump are still proposed and may change before they are finalized. CMS finalized CJR-X on July 31, 2026. The proposed cuts move value across one line of the bill; CJR-X puts the entire 90-day episode on the hospital’s books — and pays whoever can carry it and prove the outcome.
The full CJR-X breakdown, and what to do before 2028 →Source: FY2027 IPPS/LTCH Final Rule, CMS-1849-F (Federal Register 2026-15833), finalized July 31, 2026. CMS’s final CJR evaluation found net Medicare savings in performance years 6–8 (Oct 2021–Dec 2024).
READ FROM THE PRIMARY
CMS-1850-P — OPPS/ASC CY2027
91 FR 41734, July 7, 2026. The facility rule: +2.4%, the 637 inpatient-only removals, the 618 ASC additions.
CMS-1848-P — PFS CY2027
The companion physician rule. The arthroplasty work-RVU revaluation lives here, not in the OPPS rule. Comments closed September 14; final rule expected early November.
Comment docket CMS-2026-2344
Where OPPS/ASC comments were filed. Closed August 31, 2026.
ASC payment addenda
The covered-procedures and payment-indicator addenda are published on the CMS website, not in the Federal Register text.