What Are the 2027 Medicare Changes for Chiropractic?
As of July 2026, the CMS CY 2027 Physician Fee Schedule proposed rule introduces payment reductions that directly affect chiropractic practices. The proposed conversion factor decreases by 1 to 1.7 percent from 2026 rates, which reduces reimbursement for every chiropractic manipulative treatment claim (CPT 98940, 98941, and 98942) billed under Medicare. CMS also proposes a 50 percent payment reduction when a same-day E/M visit is billed alongside a procedure by the same physician or a physician in the same practice, which could affect multidisciplinary chiropractic clinics. The comment period closes September 14, 2026.
- CMT reimbursement decreasing: The conversion factor for non-APM providers drops from $33.40 to a proposed $32.84, meaning every manipulation claim submitted to Medicare will be paid less starting January 1, 2027.
- Same-day billing hit: Multidisciplinary practices that bill an E/M visit alongside CMT on the same day could see the lower-valued service reimbursed at 50 percent of its normal rate.
- Comment deadline approaching: The proposed rule is accepting public comments through September 14, 2026, and the final rule is expected later this fall.
What CMS Proposed for 2027
On July 14, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule, designated CMS-1848-P. The rule proposes payment policy changes for Medicare Part B services effective January 1, 2027. For chiropractic practices, the proposed rule contains two financial impacts that matter immediately.
First, the conversion factor is decreasing. The proposed 2027 conversion factor is $33.17 for qualifying APM participants and $32.84 for non-qualifying providers, representing cuts of 1 percent and 1.7 percent compared to 2026. Most chiropractors are not in qualifying APMs, so the 1.7 percent decrease is the number that applies to the majority of chiropractic practices. The decrease stems from the expiration of the temporary 2.5 percent payment increase Congress enacted for 2026 under the Working Families Tax Cut legislation.
Second, CMS is proposing a structural change to same-day billing. When a physician or a physician in the same practice bills a separately identifiable E/M visit on the same day as a procedure with a 0-day, 10-day, or 90-day global period, the highest-paid service would be paid at 100 percent and every additional service would be paid at only 50 percent. Chiropractic manipulative treatment codes 98940, 98941, and 98942 carry 0-day global periods. In a multidisciplinary practice where a nurse practitioner or physician assistant performs an E/M visit and the chiropractor performs the manipulation on the same day, the lower-valued service would be cut in half under this proposal.
The comment period closes September 14, 2026.
Who Do These Payment Changes Apply To?
The conversion factor decrease applies to every chiropractic practice that submits Medicare claims for spinal manipulation. If you bill CPT 98940, 98941, or 98942 under Medicare, your reimbursement per claim will be lower in 2027 under the proposed rates. This includes solo chiropractors, multi-provider chiropractic clinics, and integrated practices, regardless of geographic location. Through Chiropractor Billers, the pattern we see is that chiropractic practices with a high Medicare patient volume are the most exposed to conversion factor changes because they cannot offset the loss with private payer revenue.
The same-day E/M reduction has a more targeted scope. Under Medicare, Part B pays a chiropractor only for manual spinal manipulation to correct a subluxation, so a DC cannot be paid for an E/M visit. That means the most likely chiropractic exposure is in multidisciplinary practices where a DC shares patients with an NP, PA, or MD who bills the E/M on the same day.
One important caveat: CMS does not mention chiropractic anywhere in the proposed rule, and its language applies to services furnished by the same physician or a physician in the same group practice. Whether the reduction would reach an E/M and a manipulation billed by two different practitioners in one group is not addressed. Treat this as exposure to model and comment on, not a settled outcome.
Commercial payers frequently benchmark their payment policies to the Medicare PFS. While the same-day E/M rule is a Medicare proposal, payers that mirror Medicare’s modifier and same-day billing policies may adopt similar reductions. Practices should confirm with their top commercial payers whether they plan to follow this change.
Why CMS Is Cutting Same-Day Billing
CMS has framed the same-day E/M payment reduction as an effort to eliminate what it considers duplicative payments. The agency’s position is that when a provider performs both an E/M visit and a procedure on the same day, some of the physician work in the visit is already reflected in the procedure’s relative value units. CMS proposed a nearly identical policy in the CY 2019 PFS proposed rule but withdrew it after significant pushback from provider organizations, including the American Osteopathic Association, which confirmed that the proposal would have impacted osteopathic manipulative treatment in the same way it now targets other specialties.
The 2027 version revives the concept. Under the proposal, the most expensive service on a given day is paid in full, and every other service is reimbursed at 50 percent. For chiropractic, this creates a specific problem in multidisciplinary settings. Consider a patient who sees an NP for an E/M evaluation (coded as 99213 or 99214 with modifier 25) and then receives a chiropractic manipulation (98941) on the same date of service. Under the proposed rule, the lower-valued service on that claim would be cut in half.
One question we hear constantly from practice managers is whether restructuring the schedule so the E/M and the manipulation occur on different dates avoids the reduction. Under the current proposal, splitting the services to different calendar days would avoid the same-day rule, but that changes patient flow, creates scheduling complexity, and may not be clinically appropriate. The comment period is the window to push back on this proposal before it is finalized.
How Will This Affect Chiropractic Reimbursement?
The revenue impact depends on your Medicare patient volume, your practice model, and whether you bill E/M visits alongside manipulation. Here is a comparison of the key payment components under the proposed 2027 rule:
| Payment Component | 2026 (Current) | 2027 (Proposed) |
|---|---|---|
| Conversion factor (non-APM) | $33.40 | $32.84 (1.7% decrease) |
| CMT codes 98940-98942 | Paid at current CF rate | Paid at reduced CF rate (1.7% less per claim) |
| Same-day E/M + CMT | Both paid at 100% with modifier 25 | Lower-valued service paid at 50% |
| Therapy codes (97110, 97140) | Paid at current CF rate | Paid at reduced CF rate |
For a solo chiropractor billing 80 Medicare manipulation claims per month at 2 to 3 spinal regions (98941), the 1.7 percent conversion factor decrease alone reduces annual Medicare revenue by several hundred to over a thousand dollars depending on volume. For a multidisciplinary clinic that also bills same-day E/M visits alongside manipulation, the compounding effect of the conversion factor cut plus the 50 percent same-day reduction is significantly larger. These numbers are based on the proposed rule and could change in the final version.
What to Do Before September 14
The September 14, 2026 comment deadline is the most immediate action date. Whether or not the final rule changes, the financial modeling and billing review you do now protects your practice in either scenario:
- Pull your Medicare CMT claim volume. Run a report of every Medicare claim for CPT 98940, 98941, and 98942 from the past 12 months. Apply a 1.7 percent reduction to each claim’s allowed amount. This is your baseline revenue decrease.
- Identify same-day E/M and CMT claims. If your practice bills E/M visits alongside manipulation on the same date of service, pull those claims separately. Apply a 50 percent reduction to the lower-valued service on each one.
- Review AT modifier and documentation compliance. CMS already scrutinizes chiropractic claims heavily. The last OIG audit found that 82 percent of Medicare payments for chiropractic services were unallowable. Lower reimbursement per claim makes documentation accuracy even more critical.
- Confirm your billing partner’s awareness. If you outsource billing, verify that your billing company understands the proposed changes and can model the revenue impact for your practice.
- Contact your top commercial payers. Ask whether they plan to mirror the Medicare same-day E/M policy. Some commercial payers adopt PFS changes directly.
- Submit a public comment. The comment period closes September 14, 2026. The American Chiropractic Association and state chiropractic associations are organizing responses. The similar 2019 proposal was withdrawn after significant comment-period pushback.
Billing Mistakes This Change Will Expose
Across the billing companies we vet, a recurring pattern in chiropractic practices is that documentation and coding compliance is treated as a secondary concern until reimbursement drops and the errors start compounding. The proposed 2027 changes make several existing weak spots more costly.
The most common issue we see providers run into is omitting the AT modifier on active treatment claims or billing maintenance care as if it were active treatment. Under the current system, a denied claim can be appealed and potentially recovered. Under a system with lower per-claim reimbursement, the cost of each denied or improperly coded claim is higher relative to the revenue it was supposed to generate. A 1.7 percent cut on every allowed claim does not sound large, but when it stacks on top of a 5 to 7 percent denial rate from AT modifier errors and a 33.6 percent improper payment rate that CMS has documented for chiropractic services, the cumulative revenue loss is significant.
Practices that select the wrong CMT code for the number of spinal regions treated, fail to document subluxation to the PART standard, or bill timed therapy codes (97110, 97140) without proper documentation face an even steeper exposure. If your practice is evaluating whether your billing workflows are ready for 2027, our guide on how to find the right chiropractic medical billing service covers the key factors to consider.
In-House vs. a Chiropractic Billing Partner
Providers often come to us after a reimbursement change has already reduced their revenue, not before. The 2027 proposed rule gives chiropractic practices an opportunity to evaluate their billing operations while there is still time to prepare.
A billing company with direct chiropractic experience already understands AT modifier requirements, the active-versus-maintenance care distinction, subluxation documentation under the PART standard, and the specific CMT code selection rules for spinal regions. These are the areas where the proposed 2027 changes will create the most financial exposure, because lower per-claim reimbursement means every coding error costs more.
If your current billing team cannot model the revenue impact of the proposed conversion factor decrease, cannot tell you how many same-day E/M and CMT claims your practice files, or does not have a documented process for AT modifier compliance, those are signals that your billing operation is not positioned for what 2027 may bring. Chiropractor Billers connects practices with billing companies that specialize in chiropractic claims, not generalists who will learn the AT modifier rules after your denials spike.
The proposed 2027 conversion factor decrease hits every Medicare manipulation claim your practice submits, and the same-day E/M rule adds a second layer for multidisciplinary clinics. If your billing team cannot quantify the impact before the final rule, now is the time to connect with a chiropractic billing company that can.
Frequently Asked Questions
When do the proposed 2027 chiropractic Medicare changes take effect?
The proposed changes are part of the CY 2027 Medicare Physician Fee Schedule proposed rule and would take effect January 1, 2027, if finalized. CMS is accepting public comments through September 14, 2026, and the final rule is expected later this fall. The conversion factor decrease and the same-day E/M rule could both be modified in the final version.
Does the same-day E/M cut apply to solo chiropractic practices?
For most solo chiropractors billing only Medicare-covered manipulation, the same-day E/M rule has limited direct impact because Medicare does not pay a chiropractor for an E/M visit. The rule primarily affects multidisciplinary practices where an NP, PA, or MD bills an E/M visit on the same day that a chiropractor performs manipulation under the same practice group.
How much less will Medicare pay for chiropractic manipulation in 2027?
The proposed conversion factor for non-APM providers is $32.84, a 1.7 percent decrease from the current $33.40. Every CMT claim (98940, 98941, 98942) submitted to Medicare will be reimbursed at this lower rate. The exact dollar reduction per claim depends on the code’s relative value units and your geographic practice cost index.
Will commercial payers follow the Medicare same-day E/M rule?
It depends on the payer. Many commercial and Medicaid payers benchmark their payment policies to the Medicare PFS, but the timing and extent vary. Some adopt Medicare changes directly while others maintain separate same-day billing rules. Chiropractic practices should confirm with their top payers whether they plan to mirror this proposal if finalized.
Is this the same proposal CMS made in 2019?
CMS proposed a similar same-day E/M payment reduction in the CY 2019 PFS proposed rule but did not finalize it after significant advocacy from provider organizations, including the American Osteopathic Association. The 2027 version revives the concept. The comment period closes September 14, 2026.
Does the conversion factor decrease affect therapy codes too?
Yes. The conversion factor applies to all services billed under the PFS, including timed therapy codes such as 97110 (therapeutic exercises) and 97140 (manual therapy techniques) that chiropractic practices frequently bill alongside manipulation. Every code paid under the fee schedule will be reimbursed at the lower conversion factor rate.
Next Steps
- Pull your Medicare CMT and therapy code volume for the past 12 months and model the revenue impact of a 1.7 percent conversion factor decrease.
- If your practice bills same-day E/M visits alongside manipulation, model the additional 50 percent reduction on the lower-valued service for those claims.
- When you are ready to evaluate whether your billing partner can handle the 2027 changes, we can connect you with a chiropractic-specialized billing company in as little as 30 minutes.
The proposed 2027 Medicare changes reduce reimbursement on every chiropractic manipulation claim and add a new same-day billing penalty for multidisciplinary clinics. Whether you need a billing partner who already understands chiropractic coding, AT modifier compliance, and the PART documentation standard, or want to compare your current company’s readiness, Chiropractor Billers matches you with vetted chiropractic billing experts at no cost.
