RCM Pulse Weekly

Revenue Cycle Management Intelligence for Medical Practices
September 4, 2026
Volume 9, Issue 1
Section 01

Ten Days Left on the Last Open Comment Clock — and 119 Days Until Medicare Makes Two-Sided Risk Mandatory for Cardiology and Low Back Pain in 235 Markets

Two rulemaking clocks were running when this newsletter last published. One has since expired. The CY 2027 OPPS/ASC proposed rule (CMS-1850-P) closed for comment on August 31, 2026 — four days ago. Whatever your practice did or did not file on the Inpatient-Only list, the ASC Covered Procedures List, and the proposed 340B repricing to ASP−33.4%, that door is now shut until the final rule appears in November.

One clock is still open, and it is the bigger one. The CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), released July 14, closes for comment on September 14, 2026 — ten days from today. It is the last opportunity to influence a rule that changes how nearly every physician service in Medicare is priced.

10 days
Left to comment on the CY 2027 Physician Fee Schedule (CMS-1848-P), closing September 14
$32.8409
Proposed CY 2027 conversion factor for non-APM clinicians — down 1.68%
−2.50%
Expiration of the one-year WFTC payment increase on December 31, applied to both conversion factors
±9%
Mandatory payment adjustment range under the Ambulatory Specialty Model, live January 1, 2027
MetricCY 2027 proposedChange from CY 2026
Conversion factor — qualifying APM participants$33.1693−$0.40 / −1.19%
Conversion factor — all other clinicians$32.8409−$0.56 / −1.68%
Statutory update — QP / non-QP+0.75% / +0.25%—
Work RVU budget-neutrality adjustment+0.53%—
Expiration of the one-year WFTC increase−2.50%Applies to both conversion factors

The arithmetic is worth stating plainly: CMS is applying a small positive statutory update on top of a 2.5% cliff. The one-year payment increase Congress provided for CY 2026 expires December 31, and nothing in this rule replaces it. That is the entire explanation for how a “+0.75% update” produces a −1.19% conversion factor.

The Four Proposals That Change Practice Economics

1. The modifier 25 stacking cut. When the same physician — or another physician in the same group — furnishes a separately identifiable office or outpatient E/M visit on the same day as a procedure carrying a 0-, 10-, or 90-day global period, Medicare would pay the most expensive service at 100% and every other service on that claim at 50%. CMS’s stated rationale is overlapping physician work and practice expense. CMS is explicitly soliciting comment on whether 25% would be the more accurate reduction — which is the single most answerable question in the entire rule, and the one where a specialty-specific comment letter has the clearest path to changing a number.

2. G2211 stops being a code and becomes a modifier. Rather than a flat-dollar add-on, the complexity add-on would convert to a two-digit modifier that increases the base E/M payment by 16% — the same percentage at every visit level. A second modifier, restricted to clinicians in the Medicare Shared Savings Program and the LEAD Model, would increase qualifying E/M payment by 32%.

3. Practice expense methodology. CMS proposes to phase out its reliance on specialty-specific PE/hour data collected in 2007 or earlier, replacing it with a “PE stabilizer” intended to damp volatility without anchoring to a two-decade-old benchmark.

4. Remote monitoring tightens. RTM would be limited to established patients only, would require a separately billable initiating visit, and would have to be delivered by employed staff rather than contractors — a direct hit to the outsourced-RPM-vendor model that many small practices adopted precisely because they could not staff it internally.

CMS also proposes extending in-person visit waivers for mental health services in RHCs and FQHCs, and for non-behavioral telehealth, through December 31, 2027, aligning the regulatory calendar with the statutory telehealth extension enacted in February.

The Deadline No One Can Comment Their Way Out Of

While the comment window occupies everyone’s attention, a finalized rule is already 119 days from taking effect. The Ambulatory Specialty Model (ASM) launches January 1, 2027 — a mandatory, two-sided risk alternative payment model for specialists treating Medicare fee-for-service beneficiaries with heart failure and low back pain in outpatient settings.

The specialties pulled in are cardiology on the heart failure side, and pain management, interventional pain, neurosurgery, orthopedic surgery, and physical medicine and rehabilitation on the low back pain side.

Warning

A solo cardiologist practicing in one of the 235 selected CBSAs will be in a mandatory two-sided risk model on January 1, 2027, with a ±9% swing on Medicare Part B revenue and no application to submit, no hardship exemption to request, and no opt-out to file. If you have not checked your CBSA against the ASM participant list, that is the highest-consequence unopened item on your desk this week.

Section 02

The September 1 Payer Wave Lands: UnitedHealthcare Caps Five Lab Tests, Aetna Docks Radiology 15% Without “Smart Dose,” BCBS Michigan Starts Dismantling Incident-To

September 1 is the busiest single payer effective date of the second half of the year, and this one was heavier than usual. Six payers moved policy inside a four-day window, and the changes are not administrative housekeeping — three of them change what a practice gets paid for work it is already doing.

20
Allergens per year — new UnitedHealthcare cap for patients 20 and older, effective September 1
−15%
Aetna payment reduction on radiology billed with modifier CT lacking “Smart Dose” compliance
80%
Of the professional fee — where BCBS Michigan incident-to claims land on March 1, 2027
119 days
Until four CMS-0057-F FHIR APIs must be operational, January 1, 2027
PayerEffectiveWhat changed
UnitedHealthcareSept 1 (commercial, exchange, MA); staggered Aug–Dec for MedicaidFive new lab policies: allergen testing capped at 20 allergens per year for patients 20+; hepatic fibrosis testing limited to once per six months for HBV, HCV, MASLD, or alcoholic hepatitis; non-reimbursement for in vitro chemotherapy sensitivity and resistance assays; testosterone testing excludes asymptomatic patients; vitamin B12 capped at once per three months
AetnaSept 1Expanded Claim and Code Review Program with new claim edits; 15% payment reduction for radiology services billed with modifier CT that do not meet “Smart Dose” standards
BCBS MichiganSept 1 (Phase 1); March 1, 2027 (Phase 2)Phase 1: non-physician providers billing incident-to must append modifier SA; claims still pay at the clinician rate but become ineligible for incentive programs. Phase 2: direct billing required for clinicians with their own NPI, incident-to claims drop to 80% of the professional fee, and training-level clinicians lose office incident-to eligibility
BCBS TexasSept 424 lab-related policies updated — flow cytometry, PSA, allergen, hepatitis, thyroid, cardiovascular, micronutrient, drug testing, colorectal cancer screening
BCBS North CarolinaSept 1Multiple/bilateral surgery restructured — outpatient facility: 100% / 50% / 50% / 0% on the fourth and beyond; professional: 100% / 50% / 25% on the third and beyond
Molina Healthcare of OhioSept 1 (Medicaid)New specialty medication site-of-care policy, gene therapy coverage for Otarmeni, revised buy-and-bill policies for multiple specialty drugs, updated duplicate-claims payment integrity policy

The Michigan Change Is the One to Read Twice

Incident-to billing has been an economic assumption underneath NP and PA staffing models for two decades. BCBS Michigan is not eliminating it in one step — it is doing it in two, and Phase 1 is deliberately painless so that Phase 2 arrives inside an existing workflow. Appending modifier SA costs nothing on September 1. On March 1, 2027, the same claim, with the same modifier, pays 80%.

Any practice modeling NP/PA contribution margin on 100% incident-to reimbursement should re-run that model now, not in February. And the pattern matters more than the payer: when one Blues plan phases out incident-to economics, the others read the results.

Action Required

Pull your top 20 lab CPT codes and check them against the new UnitedHealthcare frequency caps before the first denial batch posts. Allergen panels above 20 units per year, B12 more often than quarterly, and hepatic fibrosis testing inside six months will now deny — and a frequency denial after the fact costs far more to appeal than an order-set edit costs to build.

The Federal Clock: 119 Days

The CMS-0057-F attestation deadline in HPMS passed on September 1 — three days ago. That was the payer-side checkpoint. The provider-side consequence arrives January 1, 2027 — 119 days from today, when impacted payers must operate four FHIR APIs: Patient Access, Provider Access, Payer-to-Payer, and Prior Authorization.

The Prior Authorization API is the one that changes daily work. It must support checking whether authorization is required, surfacing the specific documentation needed, electronic submission, and electronic receipt of the decision — all from inside the EHR or practice management system. The 2026 operational requirements are already live: 72 hours for expedited and seven calendar days for standard decisions, specific denial reasons, and public reporting of approval rates, denial rates, appeal outcomes, and average decision times.

Separately, the WISeR model continues in its ninth month, applying prior authorization or pre-payment review to 13 service categories — including epidural steroid injections, cervical fusion, and skin substitutes — for Traditional Medicare patients in New Jersey, Ohio, Oklahoma, Texas, Arizona, and Washington, across four MAC jurisdictions. The model runs through December 31, 2031.

Section 03

Autonomous Coding Is Now 44.8% of the AI-Coding Market and 97% Accurate in Production — 27 Days Before a 379-Code Retraining Event

Autonomous coding spent five years as the most-promised and least-deployed technology in the revenue cycle. The 2026 market data says that phase is over.

$3.86B
Global AI-in-medical-coding market in 2026, heading to $10.84B by 2034 at a 13.76% CAGR
44.8%
Share of that market held by autonomous coding tools in 2026, growing at a 36.74% CAGR
97%
Autonomous coding accuracy reported by R1 in production for ER and physician office visits
379
New codes entering production October 1 — a model-retraining event, not just a coder-education one
MetricValue
Global AI-in-medical-coding market, 2026$3.86 billion
Projected 2034$10.84 billion (13.76% CAGR)
Autonomous coding tools — share of that market in 202644.8%
Autonomous coding tools — segment CAGR36.74%
Healthcare providers — share of end-user market46.23%
North America — share of global medical coding market, 202638.8%

The accuracy numbers have moved with the market. Current production deployments report 98.5% E/M accuracy, 98.5% CPT and modifier accuracy, and 95.5% ICD accuracy, with autonomous coding rates up to 85% and direct-to-bill rates above 85% at roughly 95% accuracy without human intervention. R1 RCM reports agentic AI applications in production with select clients, including autonomous coding running at accuracy rates as high as 97% for service lines such as emergency room and physician office visits. Nym Health and Fathom remain the reference implementations, with Fathom the first autonomous coder in Epic’s App Orchard.

The Question to Ask Your Vendor This Month

Here is the part the market data does not cover, and it is the reason this section is running 27 days before October 1 rather than in January.

An autonomous coder is a trained model. On October 1, 379 new codes enter production across ICD-10-CM, ICD-10-PCS, and HCPCS Level II, with 68 deletions alongside them. A human coder handles that with a training session and a reference card. A model handles it only if someone retrained it — and only if its fallback behavior on an unmapped or newly-deleted code routes the encounter to a human queue instead of guessing at the nearest neighbor.

Three questions, in writing, to every autonomous coding and CDI vendor you use:

A vendor that cannot answer the second question has told you something important.

Meanwhile, Prior Authorization Automation Has Its Receipts

The clearest ROI in the automation stack this year is not coding — it is prior authorization, where the results are now specific enough to hold a vendor to:

Against a baseline of 13 hours per week that a physician and their staff spend on prior authorization for a single physician, those are not incremental numbers.

Generative AI
Appeal letter drafting, denial-reason interpretation, documentation gap detection, clinical summarization for medical necessity
AI / ML
Autonomous coding, denial prediction, payer behavior modeling, propensity-to-pay scoring
RPA
Eligibility checks, claim status polling, payment posting, worklist routing
Warning

Do not fund a new AI layer this quarter if your eligibility verification is still manual. Automated eligibility remains the cheapest and highest-yield automation available to a small practice, and every downstream AI investment inherits the error rate of the data underneath it.

Section 04

379 New Codes Land on a Single Day: ICD-10-CM (190), ICD-10-PCS (101), and HCPCS Level II (88) All Turn Over October 1

Most years, October 1 is an ICD-10 event. This year all three code sets that CMS controls turn over on the same date, and the HCPCS piece — posted quietly on August 18 — is the one most practices have not scheduled for.

27 days
Until all three CMS-controlled code sets turn over on October 1, 2026
190
New ICD-10-CM codes across 33 clinical topics, with 30 deletions and 4 revisions
88
New HCPCS Level II codes posted August 18 — the update most practices have not calendared
79,256
Total ICD-10-PCS codes in the FY 2027 set after 101 additions and 38 deletions
Code setNewRevisedDeletedNotes
ICD-10-CM19043033 clinical topics, nearly every chapter
ICD-10-PCS10133850 in New Technology; set totals 79,256 codes
HCPCS Level II88——Posted Aug 18; 15 requested by individuals or manufacturers
Totals — effective October 1, 202637976827 days from today

ICD-10-CM: Where the 190 Codes Actually Are

They are not evenly distributed, and one category dominates. Category O31.4 alone contributes 33 new codes for continuing pregnancy after vanishing twin syndrome of one or more fetuses, organized by trimester and encounter type. Beyond obstetrics:

HCPCS Level II: The 88-Code Update Nobody Calendared

CMS posted the quarterly HCPCS Level II update on August 18, effective October 1. Among the 88 new codes, 15 were requested by individuals or manufacturers and finalized by CMS. Notable additions with published fee amounts:

CMS is also adding 19 new HCPCS Level II codes to the home health consolidated billing non-routine supply list effective October 1 — relevant to any practice that bills supplies for patients under a home health episode, because consolidated billing determines who may bill them at all.

CPT 2027 Publishes This Month

The AMA assigns the actual five-digit numbers when the CPT 2027 code set publishes in September 2026 — this month. What is already known about January 1, 2027:

Action Required

Run clearinghouse acceptance testing on October 1 dates of service for all three code sets — not just ICD-10-CM — before the last week of September. The most common October failure is not a rejected diagnosis code; it is a supply or device HCPCS code that was valid on September 30 and is not on October 1, sitting on an otherwise clean claim.

Section 05

Expenses Per Physician Are Up 26.5% Against 9.1% Revenue Growth — Which Is Why 36% of Practices Named Automation Their Top Cost-Cutting Move

The velocity conversation has been a revenue conversation for three years: get the claim out clean, get it paid faster, work the denial. The 2026 MGMA data argues that the binding constraint has moved to the other side of the ledger.

+26.5%
Total expenses per physician versus pre-pandemic levels
+9.1%
Revenue growth over the same period — a 17-point gap
36%
Named automation their single biggest cost-cutting move for 2026
40%
Of practices employ 3+ FTE administrative staff per physician just to manage payer rules

A 17-point gap between expense growth and revenue growth cannot be closed by collecting faster. It gets closed by collecting the same dollars with less labor — which is precisely what practice leaders said they intend to do.

Where the 2026 Money Is Going

Biggest new investment in 2026 budgets (MGMA Stat, October 2025 poll): workforce 37%, health IT 30%, revenue cycle 12%, patient access 12%, other 9%.

Biggest cost-cutting move for 2026: automation 36%, process fixes 23%, hiring freeze or cuts 18%, outsourcing 14%, finding new vendors 9%. Automation and process fixes together account for more than half of all responses — the first year that pairing has outweighed headcount reduction.

Adoption is following. 43% of groups added or expanded AI in 2024; by 2025, AI tools had edged out EHR usability as the top technology priority, and 71% of practices reported using some form of AI in patient visits. 36% of practice leaders said they would outsource or automate parts of RCM, with planned investment concentrated in agentic tools for benefits and eligibility, prior authorization, payer analytics, and coding support. RCM vacancies, meanwhile, remain among the hardest roles to fill.

Where You Should Be — 2026 KPI Targets

KPIIndustry realityYour target
Days in A/R — solo / 1–3 providers45–55 typical≤ 45
Days in A/R — 4–10 providers40–48 typical≤ 40
Days in A/R — 10+ providers35–45 typical≤ 35
Days in A/R — top performers, any size—< 25
Clean claim rateIndustry benchmark 95%98–99%+
Initial denial rate11.8% average; 41% of providers above 10%≤ 5%
Medicare Advantage denial rate> 17%, up 4.8% year over yearTrack separately from traditional Medicare
Administrative FTE per physician40% of practices at 3+Measure monthly; trend it down
A/R over 90 daysVaries widely≤ 15% of total A/R

One relationship in that table is worth acting on directly: practices holding a clean claim rate above 95% consistently run days in A/R below 36. Clean claim rate is the upstream variable. A/R days is the reported one. If you can only fund one measurement discipline this quarter, measure and fix the first.

Key Insight

The KPI that best predicts whether an independent practice survives the next three years is not days in A/R. It is administrative FTE per physician — because it is the only metric that captures the expense side of the 26.5%-versus-9.1% gap, and it is the one number that automation is capable of moving.

Section 06

Technology Spotlight: The Agentic Buy-Side Gets Crowded — Candid Health’s $120M, Raintree’s Voice-Agent Acquisition, and an 86%-Denial-Reduction Platform Changing Hands

The RCM deal sheet has a pattern this year that is worth naming: the buyers are no longer RCM companies buying capacity. They are software companies buying agents — and specifically, buying the ability to put an autonomous worker inside a workflow their customers already run.

$120M
Candid Health Series D, closed July 2026, to expand autonomous end-to-end billing
86%
Denial reduction claimed by Exdion Healthcare, acquired by urgent-care platform Experity
5×
Expansion of Raintree’s AI Center of Excellence after acquiring Spike Technologies
>90%
Share of 2026 physician practice M&A transactions driven by private equity
TransactionDetail
Candid Health — $120M Series DClosed July 2026 to expand Pulse 2.0, an autonomous platform running end-to-end billing from claim submission through denial management
Raintree Systems acquires Spike TechnologiesJuly 2026; embeds agentic voice agents natively inside a rehab/PT EMR to automate payer calls, prior authorization, eligibility, and claim follow-up. Raintree’s AI Center of Excellence expanded fivefold
Experity acquires Exdion HealthcareGTCR-backed Experity reaches roughly 50% of U.S. urgent care centers; Exdion is an AI chart-to-cash platform claiming 86% denial reduction and autonomous claim processing
Adonis — $40MRaised to accelerate AI across the revenue cycle
R1 RCMAcquiring an AI platform to extend agentic applications already in production, including autonomous coding at up to 97% accuracy

Why the Vertical EMR Buyers Matter More Than the Platform Buyers

Raintree and Experity are the interesting entries, and not because the checks were the largest. Both are specialty-vertical software companies with dense installed bases — rehab and physical therapy in one case, urgent care in the other — buying agentic capability to deliver natively, inside a system their customers already log into every morning.

That is the delivery model that finally reaches a 6-physician practice. A small group will not run a procurement process for an autonomous coding vendor, negotiate an interface, and manage a second login. It will, however, turn on a feature its EMR vendor shipped. If your practice runs a specialty-specific EMR, the most consequential AI decision in your revenue cycle over the next 18 months will probably be made by your EMR vendor’s corporate development team, not by you.

Underneath all of it, private equity accounts for more than 90% of physician practice M&A transactions in 2026 — the capital structure that is funding both sides of this market.

Ten Days Out: Becker’s Health IT + Digital Health + RCM

Becker’s 11th Annual Health IT + Digital Health + RCM Conference runs September 14–17 in Chicago — 2,500+ health system leaders, 600+ speakers, 190+ sessions, with agenda tracks on mastering denials and charge capture, RCM outsourcing decisions, and revenue cycle reinvention. It is also, conveniently, the same week the PFS comment window closes.

Deal activity in this issue
Candid Health Raintree Systems Spike Technologies Experity Exdion Healthcare Adonis R1 RCM
Autonomous coding reference implementations
Nym Health Fathom Waystar Epic
Key Insight

Before evaluating any standalone agentic RCM vendor this fall, ask your existing EMR or practice management vendor a single question: what agentic capability are you shipping natively in the next 12 months, and at what price? Half of the market is being resolved by acquisition rather than by procurement, and the answer may make your evaluation unnecessary.

Section 07

Compliance Corner: September Is the Last Outreach Month — Medicaid Community Engagement Starts January 1 in 43 States and DC

Every compliance deadline in this issue is a paperwork problem except one. The Medicaid community engagement requirement is a cash flow problem, and the operational window to prepare for it closes this month.

80
Hours per month of community engagement required as a condition of Medicaid eligibility
43 + DC
States required to implement the community engagement requirement
30 days
Cure window an enrollee gets after a notice of noncompliance
10
Price transparency civil monetary penalties CMS issued in 2025 — more than double the prior pace

Under CMS-2454-IFC, beginning January 1, 2027 — 119 days from today — states must condition Medicaid eligibility for “applicable individuals” on demonstrated community engagement of 80 hours per month. The requirement reaches non-pregnant adults aged 19 to 64 who are not entitled to or enrolled in Medicare and who are eligible for or enrolled in the Medicaid adult group or certain section 1115 demonstrations. 43 states and the District of Columbia cover those populations and will be required to implement.

The timing detail that makes this a September story: states requiring an applicant to demonstrate one, two, or three months of community engagement at application had to begin outreach no later than September, August, or July 2026 respectively. September 2026 is the final outreach month for any state on the shortest lookback. Some states — Nebraska among them — have already implemented early.

Why This Lands on the Revenue Cycle, Not on Compliance

When an enrollee cannot document 80 hours, the state must send a notice of noncompliance and allow 30 calendar days to demonstrate compliance or that the requirement does not apply. Some portion of that population will not respond in time. For a practice, that produces the single worst pattern in accounts receivable: a patient who was covered at scheduling, uncovered at the date of service, and discovered at the 835.

Three controls, all front-end, all automatable:

The Rest of the Compliance Calendar

Warning

Model the revenue exposure now. Take your Medicaid adult-group volume, apply a conservative disenrollment assumption, and multiply by your average charge. That figure is your Q1 2027 self-pay conversion — and unlike a rate cut, it arrives without a comment period, a transition year, or a notice to your practice.

Section 08

Independent Practice Watch: Three Administrative FTEs Per Physician — 40% of Practices Now Staff That Way Just to Answer Payers

There is a number in the MGMA data that describes independent practice economics better than any margin figure: 40% of practices now employ three or more full-time administrative staff per physician, purely to manage payer rules, audits, appeals, and reporting requirements.

Not per practice. Per physician.

3+
Administrative FTEs per physician at 40% of practices
95%
Practice leaders reporting increased regulatory burden over the past three years
>90%
Of 2026 physician practice M&A transactions driven by private equity
≥47%
Physicians consolidated with hospital systems in 2024, from under 30% in 2012

That ratio is the mechanism of consolidation. A three-physician group carrying nine administrative FTEs has a fixed-cost base that does not shrink when Medicare cuts the conversion factor 1.68%, and cannot be amortized across the volume a 400-physician group enjoys. Every incremental payer rule widens the gap, because compliance cost scales with the number of rules, not with the number of physicians.

The Consolidation Data Underneath It

MetricValue
Share of physician practice M&A transactions driven by private equity, 2026> 90%
Physicians at PE-owned practices, 20246.5% (from 4.5% in 2022)
Practice acquisitions made by PE groups, 2019–202365%
Physicians consolidated with hospital systems, 2024≥ 47% (from < 30% in 2012)
PE-acquired practice sites, 2012 → 2021816 sites / 119 MSAs → 5,779 sites / 307 MSAs
Outpatient practices acquired by PE in January 2026 alone≥ 21

M&A activity remains strong in 2026 despite elevated interest rates and continued normalization from the 2021–2022 peak. The buyer profile has narrowed rather than broadened.

How This Week’s News Lands Differently on a Small Practice

Where You Should Be — Independent Practice Benchmarks

MetricTypical independent practiceWhere you should be
Administrative FTE per physician3+ at 40% of practicesMeasured monthly and trending down
ASM exposureUncheckedCBSA verified against the participant list this week
October 1 code readinessICD-10-CM onlyAll three code sets tested end-to-end by Sept 25
First-pass clean claim rate90–94%≥ 95%, target 98%
Days in A/R (1–3 providers)45–55≤ 45, best-in-class < 25
Initial denial rate9–12%; 41% of providers above 10%≤ 5%
Medicare Advantage denial rate> 17%Tracked and contracted against separately
Eligibility verificationManual, at registration onlyAutomated, at 3+ touchpoints including pre-submission
Medicaid eligibility recheckAt registrationRe-verified at DOS and again before claim submission
Days of cash on handOften under 30≥ 60 before Q1 2027
Action Required

Check your CBSA against the Ambulatory Specialty Model participant list this week if you employ a cardiologist, an interventional pain physician, an orthopedic surgeon, a neurosurgeon, or a PM&R physician. It is a five-minute lookup with a ±9% consequence and no appeal.

Section 09

Specialty RCM Spotlight: Radiology Loses 15% Without Dose Compliance, Cardiology and Low Back Pain Get Drafted Into Mandatory Risk, GI Gets Category I ESD Codes, and Primary Care’s G2211 Becomes a 32% ACO Modifier

SpecialtyThis week’s changeThe number
Primary CareG2211 converts from flat add-on to a percentage modifier; enhanced modifier for ACO participants+16% / +32% in MSSP and LEAD
CardiologyMandatory ASM heart failure arm; new FY 2027 cardiomyopathy codes±9% adjustment, 235 CBSAs, Jan 1, 2027
OrthopedicsASM low back pain arm; WISeR review on cervical fusion; overall PFS impact−7% overall; denial rates 14–22%
OncologyASCO impact estimate; 340B repricing; new metastatic-site codes−1.5% hem/onc, +1.5% radiation oncology
RadiologyAetna dose-compliance reduction effective Sept 1−15% on modifier CT without Smart Dose
GastroenterologyNew Category I ESD codes; G2211 replacement reworkJan 1, 2027
Behavioral HealthTelehealth secured through 2027; SBIRT and cessation join timed-code transitionDenial rates 20–30% — highest in medicine
OB / Maternal-FetalCPT maternity restructure; 33 new vanishing-twin codesFirst maternity overhaul in ~30 years

Primary Care

The G2211 redesign is the most consequential primary care payment change in the proposed rule, and the ACO provision is the part that has not been widely modeled. Converting to a 16% modifier applied uniformly across E/M levels replaces a flat dollar add-on — which advantages higher-level visits and disadvantages lower-level ones relative to today. The second modifier, restricted to Shared Savings Program and LEAD Model participants, pays 32%. CMS is also proposing new codes for shared medical appointments and advance care planning. Primary care and internal medicine continue to carry the lowest denial rates in medicine at 8–12%.

Cardiology

Two changes land simultaneously. First, the Ambulatory Specialty Model makes heart failure care a mandatory two-sided risk proposition in 235 CBSAs starting January 1, 2027, with −9% to +9% payment adjustments scored against regional peers on quality, cost, improvement activities, and interoperability. Second, on October 1, FY 2027 ICD-10-CM adds specificity that cardiology documentation is not currently written for: familial and genetic dilated cardiomyopathy distinguished from other forms, plus new codes for arrhythmogenic cardiomyopathy, CPVT, Brugada syndrome, and ventricular bigeminy. Cardiac and thoracic surgery show positive impacts in the CY 2027 specialty impact tables.

Orthopedics

Orthopedics remains the specialty carrying the largest projected downside in the CY 2027 rule at −7% overall, and is the only specialty whose overall impact includes a malpractice-RVU cut. It is now also on both sides of the utilization-control apparatus: the ASM low back pain arm covers orthopedic surgery, neurosurgery, interventional pain, pain management, and PM&R, while the WISeR model already applies prior authorization or pre-payment review to cervical fusion and epidural steroid injections in six states. Orthopedic denial rates run 14–22%.

Oncology

ASCO estimates a 1.5% overall reimbursement cut for hematology/oncology and a 1.5% increase for radiation oncology in CY 2027. Separately, the CY 2027 OPPS proposed rule — now closed for comment — would cut 340B drug payment to ASP−33.4% effective January 1, 2027, and raise the offsetting nondrug reduction from 0.5% to 3% for 2027 through 2029. On the coding side, FY 2027 adds secondary malignancy codes for specific metastatic sites including larynx, pharynx, and oral cavity that previously required nonspecific codes — better documentation, and better denial defense on medical necessity. Practices should also note UnitedHealthcare’s non-reimbursement of in vitro chemotherapy sensitivity and resistance assays effective September 1.

Radiology

The most immediately actionable item in this section. Aetna, effective September 1, applies a 15% payment reduction to radiology services billed with modifier CT that do not meet “Smart Dose” standards compliance. This is a dose-registry and equipment-attestation problem masquerading as a billing problem, and the reduction applies claim by claim. On the fee schedule side, CY 2027 impact tables project roughly +2% for diagnostic radiology and nuclear medicine and roughly +3% for interventional radiology.

Gastroenterology

The AGA’s read on the CY 2027 proposed rules is that they would reduce reimbursement for many GI services, alter complex-care payments, and introduce requirements affecting coding and billing workflow. The offsetting development is a coding win: CPT 2027 establishes Category I reporting for endoscopic submucosal dissection in both the upper and lower GI tract effective January 1, 2027 — moving ESD out of unlisted and Category III reporting. GI practices should also budget EHR and modifier-logic work for the G2211 replacement.

Behavioral Health

Behavioral health carries the highest denial rates in medicine at 20–30%, which makes every other change in this section secondary to denial management. The stability news is real: the Consolidated Appropriations Act, 2026, signed February 3, extended Medicare telehealth flexibilities through December 31, 2027, and CMS proposes extending the in-person visit waiver for mental health services in RHCs and FQHCs to match. For CY 2027, CMS proposes adding smoking and tobacco cessation and SBIRT services to the timed behavioral health code upward adjustment in its final transition year, and proposes keeping adaptive behavior codes 97151–97158 on the permanent telehealth list. Countering that: stricter 42 CFR Part 2 enforcement adds consent and documentation obligations.

OB / Maternal-Fetal Medicine

The largest single block of new ICD-10-CM codes this year belongs to obstetrics — 33 new codes in category O31.4 for continuing pregnancy after vanishing twin syndrome, stratified by trimester and encounter. Ninety-two days later, CPT 2027 restructures maternity care services for the first time in roughly three decades, effective January 1, 2027. An OB practice therefore faces two separate, unrelated code changes ninety days apart, and needs two separate testing cycles.

Section 10

This Week’s Action Items

Ten moves for the week of September 4, 2026 — each tied directly to something in this issue.

379
New codes. One day. Three code sets. On October 1, 2026 — 27 days from today — ICD-10-CM adds 190 new codes, ICD-10-PCS adds 101, and HCPCS Level II adds 88. Sixty-eight codes are deleted the same day, and the ICD-10-PCS set alone reaches 79,256 codes. Most practices have scheduled an ICD-10 refresher and nothing else — but the claim that fails on October 1 is rarely the one with an unfamiliar diagnosis. It is the clean claim carrying a supply or device HCPCS code that was valid on September 30. Ninety days later, on January 1, 2027, CPT 2027 restructures maternity care for the first time in three decades, the Ambulatory Specialty Model puts cardiology and low back pain into mandatory two-sided risk across 235 markets, four FHIR APIs come due, and Medicaid community engagement begins in 43 states. The fourth quarter of 2026 is not a coding update. It is a conversion.