On July 14, the Centers for Medicare & Medicaid Services (CMS) released the 2027 physician fee schedule (PFS) proposed rule. The proposal includes payment updates, telehealth policies, and several initiatives that could affect sleep medicine physicians and accredited sleep centers beginning Jan. 1, 2027, if finalized. The American Academy of Sleep Medicine is reviewing the proposed rule in detail and will submit formal comments to CMS before the Sept. 14 deadline. A few key highlights of the rule are summarized below.
Physician payment reductions
Although the rule includes the statutorily required annual payment updates, CMS proposes the following conversion factors for 2027:
| Conversion Factor A | Conversion Factor B |
|---|---|
| Qualifying Alternative Payment Model participants | Physicians and practitioners who are not qualifying Alternative Payment Model participants |
| $33.17 (1.19% decrease) | $32.84 (1.68% decrease) |
- CMS continues to move Medicare toward payment policies that place greater emphasis on evaluation and management (E/M) services and primary care, by proposing changes to the methodology used to value physician work and practice expense that could influence payment rates across many specialties in future years.
- The proposed rule also includes additional efforts to reduce administrative burden and modernize physician payment methodologies.
Unattended sleep testing codes
The original HSAT codes 95800, 95801, and 95806 are being deleted and will be replaced by six new codes, 95X18 through 95X23, as of Jan. 1, 2027. The new codes reflect advances in sleep technology, better capture different levels of complexity, and support a broader range of sleep disorders.
Proposed 2027 unattended sleep testing codes RVU recommendations
Technical component codes
| CPT code |
Code | RUC Recommendation |
CMS Proposed Rule |
|---|---|---|---|
| 95X18 | Unattended sleep study, setup, data acquisition, and technical analysis; low complexity of 3-4 channels that generate at least 3-5 parameter categories | 1.71 | 1.71 |
| 95X19 | Unattended sleep study, setup, data acquisition, and technical analysis; moderate complexity of 5-10 channels that generate at least 6-8 parameter categories | 1.88 | 1.88 |
| 95X20 | Unattended sleep study, setup, data acquisition, and technical analysis; high complexity of 11 or more channels that generate at least 9 parameter categories | 4.47 | 4.47 |
Professional component codes
| CPT code |
Code | RUC Recommendation |
CMS Proposed Rule |
|---|---|---|---|
| 95X21 | Unattended sleep study, interpretation and report by a physician or other qualified healthcare professional; low complexity of 3-4 channels that generate at least 3-5 parameter categories | 0.81 | 0.81 |
| 95X22 | Unattended sleep study, interpretation and report by a physician or other qualified healthcare professional; moderate complexity of 5-10 channels that generate at least 6-8 parameter categories | 1.05 | 1.05 |
| 95X23 | Unattended sleep study, interpretation and report by a physician or other qualified healthcare professional; high complexity of 11 or more channels that generate at least 9 parameter categories | 1.60 | 1.42 |
In addition to submitting comments to the proposed rule, the AASM will release a suite of educational resources over the next several months for members, vendors, and payers to support the implementation of these codes. Education will include sessions at upcoming AASM courses, new coding FAQs, several webinars, a Talking Sleep podcast episode, a cheat sheet for coders, a special module in Sleep-CODE, and template letters that clinicians can send to payers.
Potentially misvalued codes
An external entity nominated three cranial nerve neurostimulator CPT codes — 95970, 95976, and 95977 — as potentially misvalued compared with three existing phrenic nerve stimulator codes. The nominator also highlighted potential discrepancies in equipment used to perform the procedures. CMS is seeking comments on the appropriate valuation of the codes, including resource costs associated with the cranial nerve neurostimulator services.
Telehealth flexibilities continue through 2027
CMS proposes regulatory changes to implement provisions of the Consolidated Appropriations Act, 2026, that extend several Medicare telehealth flexibilities.
Notably:
- The in-person visit requirement for Medicare behavioral health telehealth services would remain suspended through Dec. 31, 2027.
- Rural health clinics and federally qualified health centers would continue to be paid for non-behavioral health telehealth services through the end of 2027.
The AASM will conduct a comprehensive analysis of the proposed rule, evaluate its impact on sleep medicine clinicians and patients, and submit comments to CMS advocating for policies that support patient access to high-quality sleep care.
Members may review the proposed rule fact sheet here and may also send questions about the proposed rule to the AASM Quality & Health Policy Team at coding@aasm.org.
