The CY2027 proposed rule hits ENT and allergy differently — with different provisions, different stakes, and different asks. Find your section below. Both deadlines close September 14, 2026.
Choose your specialty. Generate your letter. Submit.CMS proposes to pay only 50 cents on the dollar for any service billed on the same day as a procedure — the exact workflow that defines ENT practice. Otolaryngology faces one of the two largest specialty RVU cuts in the entire proposed rule. CMS withdrew nearly identical cuts in 2019 after physicians commented. The window is open again.
CMS proposed nearly identical Modifier 25 cuts in the CY2019 Physician Fee Schedule. After a strong response from specialty societies during the public comment period, CMS withdrew the proposal entirely. This year's comment deadline is September 14 — and the same opportunity exists right now.
| Specialty | Est. CY2027 RVU Impact | Primary Driver |
|---|---|---|
| Otolaryngology (ENT) | Approx. −9% | Same-day E&M + in-office procedure |
| Allergy & Immunology | Approx. −1% to −2% | Conversion factor only — allergy codes generally lack global periods |
| Dermatology | Approx. −9% | Same-day E&M + lesion procedure |
| Orthopedic Surgery | Approx. −7% | Same-day E&M + injection or casting |
| Clinical Psychology | Approx. +11% | Redistribution of RVUs |
| Clinical Social Work | Approx. +12% | Redistribution of RVUs |
There is something unusual in this year's proposed rule: CMS is asking a question it has declined to ask for years. In CMS-1848-P, CMS is soliciting public comment on two issues that sit at the center of how every allergy practice operates. ACAAI's Advocacy Council will file a formal position — but that position lands very differently when CMS reads it alongside letters from a hundred practicing allergists.
ACAAI's Advocacy Council will submit both positions as a formal society comment. But CMS weighs that differently when the same positions appear in letters from practicing allergists across the country. A brief, personal letter from your practice — describing how the 1cc definition or the 30-dose MUE affects real patients — signals that these are operational realities, not academic concerns. The window closes September 14, 2026.
Share with colleagues, professional organizations, and on social media. The more physician voices speaking up, the harder it is for CMS to ignore.
Share on LinkedInReal clinical examples are the most powerful advocacy tool we have. If you have a case that illustrates what these cuts would mean in practice, we want to hear it.
Compelling advocacy starts with real experiences. If you have a patient case or practice example that illustrates what these proposed payment changes would actually mean — on access, timing, and outcomes — your story may help inform our outreach to CMS, legislators, and coalition partners.
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