ASE Submits Comments on the CY 2027 Medicare Physician Fee Schedule Proposed Rule

On September 14, ASE submitted comments to CMS Administrator Mehmet Oz on the CY 2027 Medicare Physician Fee Schedule proposed rule, covering the conversion factor, the efficiency adjustment, practice expense methodology, site-of-service payment differentials, duplicate testing policy, AI and Software as a Medical Service payment, the mandatory Ambulatory Specialty Model, and the Quality Payment Program. ASE’s central message is that the CY 2027 rule compounds rather than corrects the instability introduced in CY 2026, retaining and expanding the 2.5% efficiency adjustment without specialty-specific evidence, rebuilding practice expense methodology on a compressed timeline, halving same-day E/M payment, and moving all quality reporting toward MVPs that contain no measure of echocardiographic quality, all while cutting the conversion factor again.

This letter is one of ASE’s most significant of the year because it addresses nearly every major payment lever affecting echocardiography at once and ties them together as a cumulative threat to practice viability. It also identifies the structural gap on that echocardiography has no quality measure, no core measure, and no MVP, meaning the shift to mandatory MVP reporting would score echocardiographers on care they do not deliver.