Understanding the CY 2027 Medicare Physician Fee Schedule: Why Neuropsychologists Should Pay Attention
NAN is working with Hopper Lundy & Bookman to advocate for the field of Neuropsychology. We recognize that the activities surrounding insurance payment for services can be complex and sometimes confusing. The following guide provides a brief overview of the various activities taking place, what they mean, and how they may impact your reimbursement.
The Medicare Physician Fee Schedule (PFS) is the primary payment system Medicare uses to reimburse physicians and other health care professionals for services provided to beneficiaries. Each year, the Centers for Medicare & Medicaid Services (CMS) updates the PFS through rulemaking, making it one of the most important federal policies affecting provider reimbursement, coverage, quality reporting, and care delivery. The CY 2027 PFS Proposed Rule was released in July 2026, with comments due September 14, 2026.
For neuropsychologists, the PFS matters because Medicare is a major payer for cognitive assessment, neuropsychological testing, dementia evaluation, and other services provided to older adults. Changes made through the PFS can affect reimbursement rates, practice operations, quality reporting requirements, and patient access to neuropsychological services. The rule also serves as a signal for future Medicare policy priorities, particularly in areas such as cognitive health, Alzheimer's disease, value-based care, and workforce development.
Key Proposals of Interest to Neuropsychology for 2027
Continued Pressure on Physician Payment
CMS proposes modest reductions to the Medicare conversion factor for 2027. Under the proposal, the conversion factor would decline to $33.1693 for qualifying Alternative Payment Model (APM) participants and $32.8409 for other clinicians, due in part to the expiration of a temporary statutory payment increase. Although these reductions are not targeted specifically at neuropsychology, they contribute to ongoing concerns about payment stability and the financial sustainability of Medicare-participating practices.
Alzheimer's Disease and Brain Health RFI
CMS included a Request for Information (RFI) seeking stakeholder input on intensive lifestyle interventions aimed at slowing cognitive decline and reducing the risk of Alzheimer's disease and related dementias. The agency is exploring how Medicare might support evidence-based interventions addressing risk factors associated with cognitive impairment and dementia. This reflects increasing federal interest in brain health, prevention, early identification, and cognitive care, all areas in which neuropsychologists possess unique expertise.
Future Reforms to Quality Reporting and Value-Based Care
CMS continues to advance efforts to transition clinicians toward value-based payment models and away from traditional reporting mechanisms. The proposed rule contains significant Quality Payment Program (QPP) provisions, including continued refinement of the Merit-based Incentive Payment System (MIPS) and eventual movement toward MIPS Value Pathways (MVPs). While neuropsychology-specific measures are limited today, these proposals could influence future quality measurement and reporting expectations for cognitive and behavioral health services.
Practice Expense Methodology Changes
CMS proposes updates to the methodology used to calculate practice expense relative value units (RVUs), which help determine payment rates across the PFS. Although the ultimate impact varies by specialty and service code, changes to practice expense valuation can affect reimbursement for services that rely on specialized staff, equipment, testing materials, and clinical infrastructure. Neuropsychology practices should monitor these proposals closely as CMS finalizes the rule.
Looking Ahead
The CY 2027 PFS Proposed Rule highlights Medicare's growing focus on early detection of cognitive impairment, Alzheimer's disease, prevention, and value-based care. At the same time, ongoing payment pressures reinforce the importance of advocacy to ensure that Medicare policies appropriately recognize the value of comprehensive neuropsychological assessment and treatment planning.
NAN will continue to monitor developments and engage with CMS on policies affecting neuropsychologists and the patients they serve. Any questions may be directed to [email protected].