Yes. CMS’s November 12, 2026 MLN Connects newsletter confirms that every physician, practitioner, and supplier enrolled in Medicare must make an active decision about participation status for calendar year 2027 by December 31, 2026, whether the plan is to keep the current status or switch it.
What Is the Annual Medicare Participation Decision?
Every year, Medicare asks each enrolled physician, practitioner, and supplier to confirm or change their participation status for the coming calendar year. CMS calls this the Annual Medicare Participation Program, and the decision window runs from mid November through December 31. The choice determines how much Medicare pays on every Part B claim that practice bills starting January 1, and how much the practice can collect directly from the patient.
Practices do not get a reminder tailored to their specialty or their revenue. The notice goes out once, in a general newsletter, and the deadline does not move. A busy November and December schedule is exactly how this decision gets missed.
What Changes for a Practice That Stays Participating?
A participating practice continues to accept assignment on every Medicare covered service, which means it agrees to accept the Medicare Physician Fee Schedule allowed amount as full payment. In exchange, Medicare pays the full allowed amount directly to the practice instead of to the patient, and Medicare forwards claim information to any Medigap insurer the patient holds, so the supplemental payment follows automatically. The practice may still collect the deductible and the coinsurance share from the patient, but nothing beyond that on a covered service.
What Changes for a Practice That Chooses Nonparticipating Status?
A nonparticipating practice is paid 5% less than the Medicare Physician Fee Schedule allowed amount on every claim. It can decide, claim by claim, whether to accept assignment. On an unassigned claim, CMS caps what the practice can charge the patient at a limiting charge of 115% of the Medicare Physician Fee Schedule amount, and the practice’s appeal rights on that claim are narrower than a participating practice’s. Collecting from the patient up front, then waiting on Medicare’s own reimbursement to the patient, changes the cash flow of every visit, not just the fee.
What Happens If a Practice Does Nothing Before December 31?
Doing nothing is itself a decision. A practice that is already participating and takes no action stays participating. A practice that is already nonparticipating and takes no action stays nonparticipating. The risk is not landing in the wrong status by accident. The risk is landing in the right status for the wrong reason, because nobody at the practice actually ran the numbers for 2027 before the window closed.
What This Means for Practices With 1 to 15 Providers
A solo or small group practice feels a 5% swing on every Part B claim far more than a large health system does, because there is no volume to absorb it and no back office team dedicated to chasing patient balances on unassigned claims. Before December 31, 2026, a practice this size should take four concrete steps.
First, pull last year’s Part B allowed amounts and model both outcomes side by side: participating pay at 100% of the fee schedule against nonparticipating pay at 95%, plus whatever share of visits would realistically be billed unassigned at the limiting charge. Second, check the practice’s current status directly with its Medicare Administrative Contractor instead of assuming, since staff turnover and past paperwork are common sources of a status nobody confirmed. Third, if a change is wanted, file Form CMS-460 or send written notice to the MAC well before December 31, since a late or missing submission locks the practice into its current status for all of 2027. Fourth, flag every patient with Medigap coverage, because participating status is what keeps that supplemental payment moving automatically instead of becoming another balance the front desk has to track down.
None of this is optional paperwork. It is a once a year lever on how much of what the practice earns in 2027 actually lands as collected revenue instead of becoming a patient balance, an appeal, or a write off.
Frequently Asked Questions
Does this decision apply to a practice that already made its choice years ago and never changed it?
Yes. The decision applies every year to every enrolled physician, practitioner, and supplier, even one that has held the same status for a decade. No action simply continues that status into 2027.
Can a practice be participating for Medicare and still bill some claims as unassigned?
No. Participating status requires accepting assignment on all Medicare covered services. Billing a claim unassigned on a case by case basis is only available to a practice with nonparticipating status.
Does the participation decision affect Medicare Advantage claims the same way?
No. The Annual Medicare Participation Program and its fee schedule percentages apply to Original Medicare Part B claims. Medicare Advantage payment follows the contract terms the practice signed with each plan, not this annual election.
What is the deadline, and is it the same every year?
The deadline is December 31, 2026 for status effective January 1, 2027. CMS runs this election every year with the same December 31 cutoff, though the specific guidance and forms are reissued annually.
A missed participation deadline, a stray unassigned claim, or a Medigap crossover that quietly stopped working are exactly the kind of leakage a Revenue Defense Audit is built to find before it costs another quarter. Request a Revenue Defense Audit from WeBill Health.
