On November 4, 2026, CMS issued the CY2027 Medicare Physician Fee Schedule final rule (CMS-1848-F), published in the Federal Register on November 9 and effective January 1, 2027. It sets the 2027 conversion factor 2.31% below 2026 for non-APM physicians — $32.6286 versus $33.40 — and 1.83% below for qualifying-APM participants at $32.9548. The size of the cut is the least interesting number in the rule. What matters is what CMS paid for everything else in the same cycle: Medicare Advantage plan payments rise 2.48%, hospital outpatient and ambulatory surgery rates rise 2.3%, and the one-time 2.50% boost that padded 2026 expires, so 2027 is the first year since that temporary increase in which Medicare asks physicians to take a cut while every adjacent Medicare price goes up.
Non-APM physician conversion factor
$32.63
CY2027 final rule, 2.31% below the 2026 rate of $33.40
Qualifying-APM conversion factor
$32.95
CY2027 final rule, down 1.83% from $33.57 in 2026
Medicare Advantage plan payments
+2.48%
CY2027 rate announcement, finalized Apr 6, 2026 — over $13 billion added
Hospital outpatient and ASC rates
+2.3%
CY2027 outpatient final rule, Nov 4, 2026
Same-day visit plus procedure
80%
second service paid at 80% instead of the 50% CMS proposed
10-year Treasury par yield
4.89%
Daily Treasury yield curve, Nov 10, 2026
Relative pricing
The Cut Is Small. The 4.79-Point Gap Between Medicare Advantage and Fee-for-Service Is Not
The arithmetic behind the headline is mechanical. A one-time 2.50% increase written into the 2026 schedule by the Working Families Tax Cut legislation does not repeat, so current law alone requires a 2.50% reduction before anything else; the statutory update adds 0.75% for qualifying APM participants and 0.25% for everyone else, and a 0.12% work-RVU adjustment takes a little more off. CMS also finished harder than it started: the non-APM cut deepened from 1.68% in the July proposal to 2.31% in the final rule. On the other side of the ledger, the April rate announcement hands Medicare Advantage plans 2.48% and more than $13 billion, and the hospital outpatient rules add 2.3%.
2027 Medicare payment updates by program
Percentage change versus CY2026, as finalized in 2026
Unit: % change vs CY2026
Physician fee schedule, non-APM
Conversion factor $32.6286
-2.3%
Physician fee schedule, APM
Conversion factor $32.9548
-1.8%
Medicare Advantage plan payments
Over $13 billion added
2.5%
Hospital outpatient and ASC
3.2% market basket less 0.9 point of productivity
2.3%
MedPAC read the same data differently. In its March 2026 report the commission recommended raising 2027 physician rates by 0.5 percentage points above current law, which after the 2.50% expiry still leaves a net decline of 1.2% for APM participants and 1.7% for other clinicians. Opens a 0.6-point gap between what CMS finalized and what the advisory panel says is adequate — and MedPAC priced the fix at $750 million to $2 billion in the first year and $1 billion to $5 billion over five.
| Program or clinician group | CMS final rule for 2027 | Change vs CY2026 | MedPAC's March 2026 recommendation |
|---|---|---|---|
| Physicians in qualifying APMs | Conversion factor $32.9548 | -1.83% | -1.2% net, 0.63 points better |
| Other clinicians | Conversion factor $32.6286 | -2.31% | -1.7% net, 0.61 points better |
| Medicare Advantage plans | +2.48%, over $13 billion | +2.48% | Set separately in the April rate announcement |
| Hospital outpatient and ASC | +2.3% update factor | +2.3% | Set separately in the outpatient final rule |
Labor supply
Physician Hours, Not the Price of an Encounter, Are the Binding Constraint
Medicare's cost index and its fee schedule have been drifting apart for a quarter-century. Over 2000–2024 the Medicare Economic Index rose 56% while cumulative fee-schedule updates rose 14%, even as fee-schedule spending per fee-for-service beneficiary rose 104%. MedPAC projects index growth of 2.2% in 2026 and 2.1% in 2027, so the 2.31% cut to non-APM physicians lands below the cost trend CMS itself projects for 2027, while the 1.83% cut to APM participants still clears it. That is not a shock, but it is a wedge opening between what a physician earns per hour and what that hour costs.
Medicare Economic Index growth falls below the size of the 2027 fee cut
MedPAC's March 2026 report: actual growth through 2025, projections for 2026 and 2027
Unit: % growth
2024
3%
2025
2.7%
2026 projected
2.2%
2027 projected
2.1%
- The AAMC projects a physician shortfall of up to 86,000 by 2036, with 20% of the clinical workforce already aged 65 and another 22% aged 55 to 64.
- The 65-and-over population is projected to grow 34.1% by 2036 and the 75-and-over cohort 54.7% — demand for physician hours rising faster than the supply of them.
- Only 38% of Medicare beneficiaries who sought a first appointment with a new primary care physician got one within two weeks, against 28% of the privately insured.
- 17% of Medicare beneficiaries say they went without care in the past year, versus 27% of the privately insured.
- 84% of medical groups report year-to-date operating costs above 2025 while 47% report higher revenue: margin, not volume, is disappearing.
The AI-care channel
CMS Paid for Outputs, Not for AI
CMS created no AI code in CY2027, and it did not need to. It opened payment for the outputs that automated and team-based care can produce while cutting the price of the physician visit that carries them. The final rule creates two advance care planning codes, establishes a national payment pathway for health and well-being coaching under general supervision, adds flexible time-based add-on codes for shared medical appointments, and boosts valuations for smoking cessation and behavioral health assessment. It also finalizes remote monitoring changes — remote therapeutic monitoring limited to established patients, a separately reportable initiating visit, updated valuations — and delays the practice-employed staffing requirement for remote monitoring to January 1, 2029.
| CMS action in the 2027 final rule | What it prices | Effective |
|---|---|---|
| Two new advance care planning codes (G0572, G0573) | Recurring planning work, not procedures | Jan 1, 2027 |
| Health and well-being coaching under general supervision | Care delivered by a team, not by the physician | Jan 1, 2027 |
| Shared medical appointments with time-based add-on codes | One clinician, many patients | Jan 1, 2027 |
| Remote monitoring: established patients, initiating visit, new valuations | Monitoring as a per-patient service | Jan 1, 2027 |
| Practice-employed staffing rule for remote monitoring, delayed two years | Contractor-delivered monitoring stays payable | Jan 1, 2029 |
| ACO Part B cost-sharing reduction and higher shared savings rates | Care management inside risk contracts | Apr 1, 2027 |
| Primary care valuation request for information | Prospective, per-patient primary care payment | Future rulemaking |
- Advance care planning gets two dedicated codes, paying for a recurring conversation a team can prepare and a physician can sign.
- Coaching under general supervision prices care that does not require a clinician to perform it personally.
- Shared medical appointments with time-based add-on codes pay one clinician for a group.
- Remote monitoring now needs an initiating visit and an established patient, but contractor staffing stays payable until January 1, 2029.
- MIPS reporting sunsets for CY2031, quality reporting moves to value pathways already covering about 98% of clinicians, and ACO electronic health record reporting is simplified.
- CMS formally reopened primary care valuation, asking how technology in primary care should be paid and whether prospective, per-patient primary care payment belongs in the Shared Savings Program or Original Medicare.
The capital layer
The Fee Cut Becomes a Credit Event Before It Becomes an Equity Event
Surgery Partners is the case study. Third-quarter revenue of $815.3 million was 0.8% below a year earlier even as same-facility revenue rose 6.0%; adjusted EBITDA slipped to $132.7 million from $136.4 million; net interest expense of $67.9 million consumed 51% of quarterly adjusted EBITDA; the company posted a $21.1 million net loss attributable to shareholders; total debt stood at $3,055.2 million and credit-agreement leverage was about 4.4 times. It then withdrew forward guidance because of a pending transaction and sold itself.
| Company | Model | Scale, latest reported | Leverage | Margin |
|---|---|---|---|---|
| Surgery Partners | Ambulatory surgery, surgical hospitals, ancillary services | $815.3M Q3 2026 revenue | 4.4x credit-agreement net leverage | Net loss of $21.1M in Q3 2026 |
| Concentra | Occupational health and urgent care clinics | $2.34B trailing revenue | 4.27x net debt/EBITDA | 29.9% gross margin, 9.2% net |
| AMN Healthcare | Travel nursing and physician staffing | $3.52B trailing revenue | 1.43x net debt/EBITDA | 28.4% gross margin, 13% revenue growth |
At $26.73 a share on November 10, 2026, Surgery Partners trades above the most the transaction can pay. That is the market's verdict on a 4.4-times-levered provider: the equity is now a deal, not a business. The same arithmetic decides who can still own physician cost. With reimbursement flat to down and the long end near 5%, the levers left are volume, labor cost and scale, and an operator carrying $3.1 billion of debt and $67.9 million of quarterly interest has none of them left. Turns a 2.31% price cut into a sale process — and hands the assets to a buyer with a lower cost of capital.
Company read-through
Who Actually Collects: The Payment-Architecture Scoreboard
Read the scoreboard as a payment-architecture table, not a performance table. Fee-for-service exposure is punished, Medicare Advantage exposure is rewarded, and the spread between them is roughly 4.79 points in 2027 alone. That does not make every aligned company a winner — it sorts them by how much of their revenue sits on each side of the line.
| Company | How it gets paid | Latest reported numbers | What the 2027 spread does to it |
|---|---|---|---|
| agilon health | Medicare Advantage capitation plus shared savings | Q3 2026 revenue $1.5B, up 6%; medical services expense ratio 88.5% versus 104.0%; net income $34.9M against a $110M loss | Sits on the +2.48% side, but MA membership fell 10% to about 453,600 and nine-month revenue was flat at $4.4B |
| Privia Health | Fee-for-service collections, capitated and shared savings | Q3 2026 revenue $657.0M; fee-for-service patient care $433.1M; capitated plus shared savings $168.4M; $446.3M cash | Two-thirds of revenue is fee-for-service, so the cut lands first; cash and no meaningful debt buy time |
| Evolent Health | Payer services and specialty value-based care | Trailing revenue $2.34B; quarterly revenue up 51%; net margin -21.7%; debt at 2.61x equity | The rate tailwind helps specialty risk contracts; negative tangible book leaves no room for a second bad year |
| HCA Healthcare | Hospital outpatient, ambulatory surgery, employed physicians | Trailing revenue $78.7B; net debt/EBITDA 3.24x | Outpatient rates rise 2.3% while employed physicians take the 2.31% cut; 340B repricing is funded by higher non-drug outpatient payments for every hospital |
| Humana | Medicare Advantage premiums and services | Trailing revenue $154.2B; net margin 0.8%; quarterly revenue up 26% with earnings down 18% | The 2.48% increase is revenue, not margin: it funds utilization first |
- AMN Healthcare is the cleanest way to own the shortage without the balance sheet: trailing revenue of $3.52 billion, 13% revenue growth in the latest quarter, a 28.4% gross margin and 1.43 times net leverage.
- Tempus AI is an option on the new architecture rather than a beneficiary of it: trailing revenue of $1.51 billion growing 23% in the latest quarter at a 64.5% gross margin, but a -12.5% net margin and no Medicare code that pays for an algorithm.
- Care migrates to whoever is paid for the episode: hospitals keep the 2.3% outpatient update while their employed physicians take the 2.31% cut, and off-campus hospital imaging moves to fee-schedule-equivalent rates.
Horizons
What Moves First, What Compounds
The calendar that decides this
Dec 31, 2026
FY2027 appropriations
Congress can add MedPAC's 0.5 points
Jan 1, 2027
CY2027 fee schedule effective
$32.6286 conversion factor; 80% same-day rule
Mar 1, 2027
Ticking fee starts
10% a year on the $25.00 cash price
Apr 1, 2027
ACO cost-sharing changes
Part B cost sharing can be reduced or waived
Early Jul 2027
CY2028 proposed rule
CMS must answer primary care valuation and technology
Oct 23, 2027
Merger outside date
$1.61 a share maximum ticking fee
Jan 1, 2029
Remote monitoring staffing rule
Practice-employed clinical staff or no payment
- By December 31, 2026: the FY2027 appropriations bill decides whether MedPAC's 0.5-point recommendation lands, which would shrink the non-APM reduction from 2.31% to 1.7%.
- January 1, 2027: the conversion factor resets to $32.6286, the same-day visit-plus-procedure rule pays the second service at 80%, and remote monitoring requires an initiating visit and an established patient.
- March 1, 2027: if the Surgery Partners transaction clears shareholders but has not closed, the 10%-a-year ticking fee starts accruing.
- April 1, 2027: accountable care organizations can begin eliminating or reducing Part B cost-sharing, raising the value of shared-savings economics for the groups that already collect it.
- By early July 2027: the CY2028 physician fee schedule proposed rule is where CMS has to answer the primary care valuation and technology-in-primary-care questions it took comments on.
- January 1, 2029: the practice-employed staffing requirement for remote monitoring takes effect — the two-year delay is the window in which contractor-delivered monitoring scales.
- CY2031: MIPS reporting sunsets and quality reporting runs on value pathways, with at least one specialty-specific core measure required from 2027.
- By 2036: an 86,000-physician shortfall and a 54.7% larger 75-and-over population decide whether the productivity came from technology or from access limits.
Three things would break this thesis. Congress can restore the cut in December and hand fee-for-service physicians a flat-to-up 2027. Medicare Advantage can go the other way: the rate announcement is set once a year, and a plan year of worse-than-expected utilization can absorb a 2.48% increase without adding a cent to provider rates. And the productivity bet can fail — if AI-assisted documentation does not actually free up physician hours, the only remaining adjustment is volume, and volume is exactly what the access data says there is no room for. The clean test is whether primary care visits per physician rise in 2027 without appointment waits getting longer.
Synthesis
A Small Price Change With a Large Consequence
The investable conclusion is not that a 1.8% to 2.3% price change breaks the physician business; a program whose cost index has run 56% against 14% of cumulative updates absorbs such cuts for years. It is that CMS in 2026 chose to pay for care around the physician and less for the physician's own hour, while Medicare Advantage and hospital outpatient prices went up. Moves the margin pool from physician labor toward platforms, teams and whoever owns the patient's episode. The exposures that fit the mechanism are labor scarcity carried on a workable balance sheet, per-patient payment architecture with scale and cash, and — for the levered operators — a credit instrument rather than a growth story.
The investable read-through
- Fee-for-service patient care was $433.1M of $657.0M in Q3 2026 revenue, so the 2.31% conversion-factor cut lands on the largest line first.
- Capitated revenue of $99.5M plus $68.8M of shared savings sits on the Medicare Advantage side that gains 2.48% in 2027.
- $446.3M of cash and no meaningful debt let Privia buy scale while fee-for-service independents shrink.
- Horizon: watch fee-for-service growth, up 22.8% in Q3 2026, and the reopened primary care valuation file.
- Q3 2026 net income of $34.9M against a $110.0M loss a year earlier shows the model works when the medical services expense ratio falls to 88.5% from 104.0%.
- MA membership fell 10% to about 453,600, so the 2.48% rate increase is not enough on its own.
- At 0.29x trailing sales after the 1-for-25 reverse split, the operating turnaround is not priced, but the forward multiple is 178x.
- Horizon: membership disclosure each quarter is the near-term test; the CY2028 primary care valuation rule is the 2027 story.
- Trailing revenue of $2.34B and 51% quarterly revenue growth come with a -21.7% net margin and debt at 2.61x equity, so the rate tailwind funds losses rather than profits.
- Evolent sells the shift from fee-for-service to risk, the direction CMS is paying for; its payer partners face the same 2.31% cut.
- Tangible book value of -$7.61 a share leaves no room for a second impairment if specialty utilization rises.
- Horizon: 2027 payer contract renewals set risk rates; owning oncology and cardiology risk books pays if primary care payment goes prospective.
- Trailing revenue of $3.52B with 13% growth in the latest quarter at a 28.4% gross margin turns a structural shortage into billable placement volume.
- At 1.43x net debt/EBITDA and 13.8x trailing earnings, AMN carries the labor trade without the 4.3x to 4.4x leverage forcing provider exits.
- Every fee cut pushes hospital-employed budgets toward contract and locum coverage rather than salaried hiring.
- Horizon: locum and allied bill rates and vacancy days are the near-term read; the 86,000-physician shortfall is the structural bid.
- Leverage of about 4.4x and $67.9M of quarterly interest against $132.7M of adjusted EBITDA forces the equity into a deal rather than a turnaround.
- The $25.00 cash price plus a 10%-a-year ticking fee caps consideration at $26.61, below the $26.73 close on November 10, 2026.
- Guidance was withdrawn because of the pending $5.7 billion enterprise-value transaction, leaving no company forecast to underwrite.
- Horizon: shareholder vote and closing, with the ticking fee accruing from March 1, 2027 and an October 23, 2027 outside date.
- Trailing revenue of $1.51B growing 23% in the latest quarter at a 64.5% gross margin is a diagnostics business, not a Medicare-funded one.
- No 2027 code pays for an algorithm: CMS asked how ambient documentation and clinical decision support should affect payment, and answers are due in a later rule.
- A -12.5% net margin means the equity prices a payment framework CMS has not yet written.
- Horizon: the CY2028 proposed rule due by early July 2027 is the single date that decides the thesis.
- Trailing revenue of $78.7B and 3.24x net debt/EBITDA make HCA the scale operator that can absorb a 2.31% cut to employed physician pay.
- Outpatient rates rise 2.3% in 2027 and 340B repricing is funded by higher non-drug outpatient payments for every hospital, so the hospital side of the same rule cycle is paid more.
- Off-campus hospital imaging moves to fee-schedule-equivalent rates, trimming the hospital's imaging advantage.
- Horizon: the shift from sick care to chronic and ambulatory management pulls revenue toward outpatient departments; 340B is a 2027 step, not a trend.
- Medicare Advantage payments rise 2.48% in 2027, adding revenue to $154.2B of trailing revenue at a 0.8% net margin.
- Quarterly revenue grew 26.1% while earnings fell 17.9%, so the rate increase is being spent on utilization, not margin.
- A shrinking fee-for-service physician base raises what plans must pay networks, which is where the spread bites back.
- Horizon: the January 1, 2027 rate year and the 2027 bid are near-term catalysts; prospective primary care payment changes plan economics over three years.
