How Does the 2027 Medicare Fee Schedule Affect Podiatry Billing?
As of July 2026, the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) specifically identifies podiatry as one of the specialties facing a large negative impact from proposed payment changes. The primary driver is a proposed 50% reduction in E/M visit payments when billed on the same day as a procedure with a global surgical period. Because podiatry practices routinely perform in-office procedures alongside evaluations, this change targets the billing pattern that generates a significant portion of podiatric revenue.
CMS names podiatry specifically:
The proposed rule analysis flags podiatry alongside dermatology and otolaryngology as specialties facing the largest negative payment impact from the same-day E/M and global period overlap proposal.
Same-day procedures drive the cut:
Nail procedures, fracture care, wound debridement, casting, and other in-office treatments billed with a separate E/M visit would see the E/M component reduced to 50% of the allowed amount.
Conversion factor drops too:
The overall conversion factor would fall 1.68% for non-APM practitioners, compounding the same-day billing reduction on every Medicare claim.
What CMS Proposed for Podiatry
On July 14, 2026, CMS published the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P). The proposed rule includes a change to how Medicare pays when a separately identifiable E/M visit, billed with Modifier 25, is furnished on the same day as a procedure with a 0-, 10-, or 90-day global surgical period.
Under the proposal, the most expensive service would be paid at 100% and all other services billed on the same day would drop to 50% of their allowed amount. CMS stated in the proposed rule that it believes this policy accounts for overlap between the E/M resources already incorporated into global surgical packages and the separately billed E/M visit.
CMS specifically expects this proposal to have a large negative impact on podiatry, dermatology, and otolaryngology. These three specialties share a common billing pattern: high-volume in-office procedures performed during the same visit as a clinical evaluation. For podiatry, this describes the majority of Medicare encounters.
The conversion factor would also decrease to $32.8409 for non-APM participants, a 1.68% reduction from 2026. The G2211 visit complexity add-on code transitions to a modifier that increases the E/M payment by 16% for qualifying complex visits, but this offset is limited to encounters meeting the longitudinal care criteria.
Which Podiatry Procedures Are Most Affected?
The same-day E/M reduction targets any encounter where a podiatrist bills Modifier 25 on an E/M code alongside a procedure with a global period. In a typical podiatry practice, that covers the core of daily operations.
Nail avulsion (CPT 11730) and matrixectomy (CPT 11750) are among the highest-volume same-day procedure and E/M pairings in podiatry. Nearly every ingrown toenail treatment includes a separately identifiable evaluation. Under the proposal, the evaluation portion drops to 50%. For a closer look at nail procedure billing rules, see our guide to CPT 11730.
Metatarsal fracture treatment (CPT 28450) with same-day evaluation is another common pairing. The E/M visit documents the injury assessment, treatment decision, and follow-up plan, while the fracture code covers the actual treatment. Both are clinically necessary and separately identifiable, but under the proposed rule, the lower-valued service gets cut in half. Our CPT 28450 billing guide details the documentation requirements for this code.
Wound debridement, casting and strapping (CPT 29405), wart destruction, corn and callus trimming in at-risk patients, and injection procedures all follow the same pattern. In every case, the podiatrist evaluates the patient, determines a treatment plan, and performs the procedure in the same visit. The proposed rule treats the E/M as partially duplicative of the global period, which reduces the E/M payment.
What Does This Cost a Podiatry Practice?
Across the billing companies we vet for podiatry practices, the most common same-day billing volume we see is 15 to 25 Modifier 25 encounters per day for a busy solo podiatrist. At an average E/M allowed amount of $85 for a level-3 office visit, a 50% reduction means roughly $42.50 lost per encounter.
For a solo podiatrist billing 20 same-day encounters per day across 22 working days, the monthly revenue loss from the E/M reduction alone is approximately $18,700. Over a full year, that exceeds $224,000 in lost E/M revenue from a single practice.
Group practices with multiple podiatrists face proportionally larger exposure. A three-podiatrist practice with combined same-day volume of 50 encounters per day would lose roughly $46,750 per month, or over $561,000 per year.
These figures assume the full 50% reduction applies to every same-day encounter. The G2211 complexity modifier transition would offset approximately $13.60 per qualifying visit (16% of an $85 E/M), but only for encounters that meet the longitudinal care criteria. Routine podiatric procedures in otherwise healthy patients are unlikely to qualify, limiting the offset to a fraction of total volume.
How to Protect Podiatry Revenue in 2027
The comment period closes September 14, 2026, and CMS proposed a similar change in 2019 without finalizing it. But podiatry practices should prepare regardless:
- Calculate your same-day Modifier 25 volume. Pull every claim from the last 12 months where Modifier 25 was appended to an E/M code alongside a procedure with a global period. This is your financial baseline.
- Model the 50% E/M reduction against your actual allowed amounts. The annualized loss tells you exactly how much revenue is at risk and whether your practice can absorb it or needs to adjust operations.
- Verify your E/M coding levels on procedure days. If your billing defaults to level-3 E/M on every procedure visit, you may be undercoding encounters that support a level-4. At 50% payment, the difference between levels is $15 to $25 per encounter. For a complete reference, see our podiatry billing and coding cheat sheet.
- Audit G2211 eligibility across your patient panel. Diabetic foot care patients, chronic wound patients, and patients with peripheral vascular disease often meet the complexity criteria for the 16% E/M modifier. Capturing this where it applies creates a partial buffer.
- Review your documentation for Modifier 25 compliance. The note must demonstrate the E/M was separately identifiable from the procedure. A note describing only the procedure without a distinct evaluation component will be denied under current rules and carries higher audit risk under the proposed framework.
- Submit a public comment to CMS by September 14. The American Podiatric Medical Association is expected to advocate strongly against this proposal. Individual practice comments quantifying the real-world financial impact strengthen the case.
Podiatry is one of the specialties CMS specifically identifies as facing the largest negative impact from the 2027 fee schedule proposal.
If your practice is not sure how the Modifier 25 change, the conversion factor cut, and the G2211 transition interact on your specific code mix, a billing partner who specializes in podiatry can model it for you. We match podiatry practices with billing companies that understand foot and ankle coding at the procedure level.
Common Podiatry Billing Errors That Compound the Cut
The practices that will feel the 2027 changes most acutely are not the ones with the highest same-day volume. They are the ones with the highest same-day volume combined with existing billing errors that already reduce revenue below what the practice should be collecting.
- Defaulting to a level-3 E/M on every procedure visit. Many podiatry practices bill 99213 on same-day procedure encounters regardless of the actual medical decision-making complexity. A diabetic patient presenting with a nonhealing wound and a concurrent nail disorder supports a level-4 or level-5 E/M. At 50% payment, every undercoded level represents $15 to $30 per encounter in lost revenue.
- Skipping the E/M entirely to avoid Modifier 25 scrutiny. Some practices stop billing the same-day E/M because they are concerned about Modifier 25 denials. This sacrifices 50% of the E/M revenue (under the proposed rule) when they could be collecting the full 50% with proper documentation.
- Failing to distinguish routine foot care from covered podiatric services. Medicare covers foot care only when the patient has a qualifying systemic condition. Mixing up routine care exclusions with covered procedural services produces denials that have nothing to do with the Modifier 25 proposal but contribute to the same revenue erosion.
- Not tracking global period assignments for each procedure code. If a procedure code’s global period is incorrectly assigned in the practice management system, the payer may apply the same-day reduction to encounters that should not be subject to it, or deny the E/M claim outright.
2026 vs. 2027 Podiatry Billing Comparison
| Billing Element | Current (2026) | Proposed (2027) |
|---|---|---|
| Conversion factor (non-APM) | $33.40 | $32.84 (-1.68%) |
| Nail avulsion (11730) + level-3 E/M (Mod 25) | Both at 100% | E/M at 50%; procedure at 100% |
| Estimated E/M loss per nail procedure encounter | $0 | ~$42 to $45 |
| G2211 offset (if qualifying) | Flat add-on | 16% E/M increase (~$13.60 per visit) |
| CMS projected specialty impact | N/A | Large negative impact (named specifically) |
| Monthly impact: solo podiatrist, 20 encounters/day | N/A | ~$18,700 loss |
These are estimates based on proposed RVUs and typical podiatry allowed amounts. The final values will be published in the November 2026 final rule. Practices should model the impact using their own payer-specific allowed amounts and encounter volume data.
Frequently Asked Questions
No. As of July 2026, this is a proposed change in CMS-1848-P. CMS accepts public comments through September 14, 2026. A similar Modifier 25 proposal in 2019 was not finalized. The final rule typically publishes in November, and the APMA is expected to advocate against the proposal.
Podiatry is a procedure-heavy specialty where same-day E/M visits with Modifier 25 are billed on the majority of Medicare encounters. The proposed 50% reduction on same-day E/M services disproportionately affects specialties with this billing pattern. CMS identified the financial exposure as large for podiatry specifically.
The proposed rule applies to Medicare Part B. Commercial payers set their own same-day billing policies independently. However, some commercial plans benchmark against Medicare rules, so a finalized change could influence commercial payer behavior over time.
Partially. The proposed 16% E/M modifier applies to visits involving complex, longitudinal patient care. Podiatry patients with diabetes, peripheral vascular disease, or chronic wound management may qualify. Routine nail care encounters without ongoing complexity typically do not.
Quantify your same-day Modifier 25 volume, model the financial impact, audit your E/M coding levels, verify G2211 eligibility for chronic disease patients, and consider submitting a public comment to CMS describing the revenue impact on your specific practice.
The proposed changes do not require a switch, but they do require a billing company with podiatry-specific expertise in procedure coding, modifier compliance, and Medicare foot care coverage rules. If your current billing partner has not modeled the 2027 impact or audited your same-day billing accuracy, that is a gap worth addressing.
Next Steps
- Pull your same-day Modifier 25 claim volume and calculate the annualized revenue at risk under the proposed 50% reduction.
- Review our podiatry billing and coding cheat sheet to confirm your coding aligns with 2027 documentation requirements.
- Request a free quote to compare podiatry billing companies that specialize in foot and ankle coding, Modifier 25 compliance, and Medicare foot care rules.
CMS has put podiatry on notice.
The 2027 fee schedule proposal targets the exact billing pattern that drives podiatric revenue: same-day evaluation and procedure. The practices that protect their bottom line will be the ones with accurate E/M leveling, clean Modifier 25 documentation, and a billing partner who understands podiatry coding at the CPT level. We match podiatry practices with billing companies built for this specialty. Every quote is free.
