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Yes. For most multi-location optometry groups, the proposed rule would reduce Medicare revenue in 2027, and the conversion factor cut is the smallest piece of it. CMS proposed lowering the non-QP conversion factor to $32.84, down 1.68% from $33.40 in 2026. The bigger risk comes from three policy changes most optometry billing teams haven’t modeled yet: a 50% payment cut on same-day E/M and procedure visits, a rework of how practice expense is calculated, and the end of Traditional MIPS.
Groups that measure these risks before the final rule arrives in November can protect most of the revenue at stake. Groups that wait will see the damage in their first 2027 remittances.
What the CY 2027 Proposed Rule Changes for Optometry Billing
CMS published the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, 2026. The comment period closed on September 14, and the final rule usually follows in early November. That leaves optometry billing teams about eight weeks to prepare before the new rates take effect on January 1.
How much of this reaches your bottom line depends on your payer mix. The more of your revenue that comes from medical eye care rather than vision plans and eyewear, the more of these changes you’ll feel. Groups that manage glaucoma, diabetic eye disease, dry eye, and urgent eye problems carry the most exposure.
The base cut isn’t a policy choice by CMS. Congress gave physicians a one-time 2.5% payment increase for 2026, and that increase expires on December 31. The small statutory updates and a 0.53% budget neutrality adjustment don’t make up the difference. Since most optometrists don’t qualify as Advanced APM participants, the 1.68% non-QP cut is the number that applies.
For a medical-model optometry group billing $2M a year in Medicare Part B allowed charges, that cut alone takes roughly $33,600 out of 2027 revenue before any other policy change is counted.
The Modifier 25 Proposal: Optometry’s Largest Hidden Exposure
This is the change optometry CFOs should watch most closely. Today, when a provider performs a significant, separately identifiable E/M service and a minor procedure on the same day, Medicare pays both in full with modifier 25 on the E/M.
CMS now proposes to pay only the higher-valued of the two at 100%. Every other service in that visit with a 0-, 10-, or 90-day global period would be paid at 50%. The rule would apply across the whole group, not just to the individual provider.
Medical optometry produces this kind of visit every day. A patient comes in with a corneal foreign body, ingrown lashes, or dry eye that needs punctal plugs. The optometrist evaluates the problem and treats it in the same visit. Under the proposal, whichever service pays less gets cut in half.
Here’s what that looks like in numbers. Take an 8-location, medical-model optometry group with 1,600 same-day E/M and procedure visits a year, where the lower-paid service averages $70 in allowed charges. A 50% cut on those services costs the group about $56,000 a year.
The final percentage isn’t settled. CMS asked for public comment on whether 25% would be a more accurate reduction than 50%. Physician organizations have pushed back hard. The AMA and a coalition of specialty societies asked CMS to drop the policy entirely, pointing out that CMS rejected a very similar idea in 2019 and hasn’t shown new evidence that these visits are overpaid.
There’s one detail that matters for optometry in particular. As written, the cut applies to office and outpatient E/M codes (99202 through 99215). Many optometrists bill medical visits using the eye exam codes (92002 through 92014) instead.
Once the final rule is published, optometry billing and coding leaders should check whether visits billed with 920xx codes fall inside or outside the policy. If they fall outside, choosing the right code family becomes a real revenue decision, as long as the documentation supports it.
Practice Expense Changes and MIPS: The Slower Risks
CMS also wants to change how it spreads indirect costs like rent, front-desk staff, and overhead across specialties. The current method relies on survey data for each specialty, called the Indirect Practice Cost Index (IPCI). CMS proposes cutting that index’s influence in half in 2027 and removing it completely in 2028.
How this hits an optometry group depends on where its doctors work. Office-based optometry came out ahead in last year’s changes, with standalone offices projected to gain about 3% in practice expense payments while facility-based work faced a cut of about 13%. Groups with optometrists working in hospital outpatient departments or co-managing surgical patients through ASCs should model both years of the change, not just 2027.
Quality reporting carries the biggest potential loss. CMS proposes ending Traditional MIPS, requiring MIPS Value Pathways (MVPs), and adding a required core measure. The maximum MIPS penalty is 9%, so a group with a $2M Medicare book could lose up to $180,000 if its reporting setup isn’t ready for MVPs when the 2027 performance year starts.
There’s also money to gain. CMS proposes replacing the G2211 add-on code with a modifier that raises payment for qualifying office E/M visits by 16%. Optometry groups that manage glaucoma, diabetic retinopathy, and other long-term eye conditions are strong candidates, but only if their notes clearly show an ongoing care relationship with the patient.
2027 Optometry Margin Exposure at a Glance
| Proposed Change | How It Works | Modeled Exposure ($2M Medicare Book) | What Groups Can Do |
| Conversion factor cut | 2026’s 2.5% increase expires | About $33,600 (1.68%) | Renegotiate commercial contracts to offset Medicare loss |
| Modifier 25 same-day reduction | Lower-paid service paid at 50% | About $56,000 (1,600 visits) | Review code choice, visit patterns, and documentation |
| IPCI phase-out | Indirect costs recalculated, half in 2027 | Depends on site of service | Model each location separately |
| MIPS to MVP transition | Traditional MIPS ends | Up to $180,000 (9% max penalty) | Pick an MVP and test reporting in Q4 |
| G2211 replaced by 16% modifier | Percentage add-on to E/M visits | Revenue gain opportunity | Document ongoing care relationships |
These figures are illustrations for a hypothetical 8-location, medical-model group, not CMS estimates. Each group’s actual exposure depends on its payer mix, code mix, visit volume, and the final rule’s wording.
How Multi-Location Optometry Groups Should Prepare Now
The groups that hold their margin in 2027 will act before the final rule, not after. Start by pulling 12 months of optometry billing data and counting every same-day modifier 25 visit by location and provider. Then flag which procedure codes carry 0- or 10-day global periods, since those are the ones affected.
Where it makes clinical sense, and only where it does, look at whether some procedures could be scheduled on a separate visit. Finally, choose an MVP now and run a test submission in Q4, while there’s still time to fix gaps in your data.
MBC’s coders work with these decisions daily. They know when to use 920xx versus 992xx codes, how co-management modifiers 54 and 55 work, and what documentation holds up when a modifier 25 claim gets audited. Explore our full range of specialty billing services or review our RCM pricing models for multi-location groups.
Summary
The CY 2027 proposed rule would cut the non-QP conversion factor by 1.68%, but optometry’s larger risks come from the modifier 25 same-day payment cut, the phase-out of the indirect cost index, and the required move from Traditional MIPS to MVPs.
A modeled 8-location, medical-model group with a $2M Medicare book faces about $90,000 in combined losses from the conversion factor and modifier 25 changes, with up to $180,000 more at risk from MIPS penalties.
Groups with more medical eye care in their payer mix will feel these changes most. The new 16% E/M modifier can offset part of the loss for groups with strong documentation of ongoing care. The final rule is expected in early November 2026, and the work to prepare should start now.
See What the 2027 Rule Means for Your Group
The same proposed rule can cost one optometry group $25,000 and another $100,000. The difference comes down to how much of your revenue is medical eye care, how often your doctors pair exams with minor procedures, which exam codes they bill, where they see patients, and how ready your quality reporting is for MVPs.
MBC’s optometry medical billing team reviews your Medicare claims, puts a dollar figure on each proposed change, and lists the specific fixes to make before January 1. We’ll run your numbers against the proposed rule now and update them when the final rule is out, so you’re not planning twice. Schedule your review, call 888-357-3226, or email info@medicalbillersandcoders.com.
FAQs: Optometry Billing
No, it’s still a proposed rule. CMS usually releases the final version in early November, and parts like the modifier 25 cut could be changed, lowered to 25%, or dropped.
Most optometrists aren’t Advanced APM participants, so they face a 1.68% cut, from $33.40 to $32.84. That works out to about $16,800 for every $1M in Medicare allowed charges.
Yes, when an office E/M visit is billed on the same day as a procedure with a 0-, 10-, or 90-day global period. Foreign body removal, lash epilation, and punctal plug insertion are common examples in optometry.
CMS proposes replacing G2211 with a modifier that adds 16% to qualifying E/M visits. Optometrists who manage chronic eye disease may qualify if their documentation supports it.
Count same-day E/M and procedure visits, review how often 920xx and 992xx codes are used, choose an MVP for quality reporting, and estimate the financial impact at each location.
Source: CMS Physician Fee Schedule, CY 2027 Proposed Rule (CMS-1848-P)
A Subject Matter Expert in healthcare billing operations with nearly 10 years of experience, sharing insights on claims processing, coding support, and revenue cycle optimization. Dedicated to educating healthcare professionals on compliance, accuracy, and strategies to improve billing performance.
