The Centers for Medicare & Medicaid Services (CMS) has proposed significant changes to the 2027 Medicare Physician Fee Schedule that could have a substantial impact on orthopaedic surgeons, physician practices and, ultimately, patients’ access to musculoskeletal care.
At the Tennessee Orthopaedic Society’s recent Annual Meeting, Dr. Adam Bruggeman provided an overview of several of the proposed changes and discussed their potential implications for orthopaedic practices. One important takeaway from that presentation was clear: individual physician comments matter.
The public comment period is currently open and closes Sept. 14, 2026.
Proposed Changes Could Affect Orthopaedic Practices
Several provisions in the proposed rule are of particular concern to the orthopaedic community, including:
- Significant proposed reductions in reimbursement for total hip and knee arthroplasty
- A proposed 50% reduction involving separately identifiable same-day evaluation and management services and certain global surgical services
- Continued pressure on physician payments through budget neutrality and proposed efficiency adjustments
- Changes to practice expense methodology and assumptions regarding the work performed during the global surgical period
While each proposal is significant on its own, the cumulative effect could create additional financial pressure for physician practices that are already facing rising costs.
Physician reimbursement has not kept pace with inflation, while the costs associated with staffing, technology, malpractice insurance, regulatory compliance and other aspects of delivering care continue to increase. At the same time, patients are becoming increasingly medically complex and often require greater coordination and resources before and after surgery.
This Is About More Than Reimbursement
The impact of these proposed changes extends beyond physician compensation.
Sustainable orthopaedic practices are essential to maintaining access to musculoskeletal care across Tennessee. Orthopaedic surgeons help patients remain mobile, independent and active, and local practices support thousands of nurses, medical assistants, therapists, radiology technicians, schedulers, coders and other health care professionals throughout Tennessee communities.
Changes that make it increasingly difficult to maintain sustainable practices could ultimately affect the availability and accessibility of care for patients.
TOS Encourages Physicians to Make Their Voices Heard
To make the process easier, TOS has developed a one-page comment guide based on publicly available information and the issues discussed during Dr. Bruggeman’s Annual Meeting presentation. The guide provides key talking points and instructions for submitting comments.
Physicians are encouraged not to simply submit a form letter. Instead, personalize comments based on your own experience, practice environment and the potential impact these proposals could have on your patients.
Even a brief, thoughtful comment can make a difference, and the process should take less than 10 minutes.
Comment deadline: Sept. 14, 2026
CMS Docket: CMS-2026-2377
The TOS comment guide includes instructions and a direct link for submitting comments to CMS.
TOS encourages members to take a few minutes to participate in the public comment process and to share the information with partners and other orthopaedic colleagues.
Advocacy is an important part of protecting access to quality orthopaedic care. Make your voice heard and help advocate for patients and orthopaedic care across Tennessee.