RCM Pulse Weekly

Revenue Cycle Management Intelligence for Medical Practices
October 2, 2026
Volume 10, Issue 1
Section 01

Medicare Finalizes GLOBE: A Mandatory Five-Year Part B Drug Model Tied to 19 Countries’ Prices Starts January 1 in Areas Holding 25% of Original Medicare — With Savings Cut From $2.3 Billion a Year to $80 Million

On September 30, 2026, CMS finalized the Global Benchmark for Efficient Drug Pricing (GLOBE) Model — a mandatory, five-year test that links Medicare Part B payment for certain high-spend physician-administered drugs to net prices in 19 developed countries, including Canada, France, Germany, Japan, and the United Kingdom. Earlier September issues of this newsletter tracked GLOBE as a pending proposal. It is now a rule, and it starts in 91 days.

25%
Share of Original Medicare beneficiaries living in the randomly selected GLOBE geographic areas
19
Reference countries used to set international price benchmarks
$80M
CMS’s projected annual Part B savings, down from about $2.3 billion in the proposal
Apr 1, 2027
Date lower GLOBE coinsurance begins for beneficiaries

What Is in Scope

GLOBE applies to single-source drugs and sole-source biologicals in oncology, rheumatology, immunology, ophthalmology, and endocrinology with more than $100 million in annual Original Medicare spending. Excluded: biosimilars, reference biologicals once a biosimilar enters the market, orphan-only drugs, plasma-derived products, certain cell and gene therapies, and drugs already under negotiated prices.

GLOBE milestoneDate
Final ruleSeptember 30, 2026
Model start (delayed from October 2026 in the proposal)January 1, 2027
Lower beneficiary coinsurance beginsApril 1, 2027
Model performance period endsMarch 31, 2032
Rebate reconciliation endsMarch 31, 2034

How the Money Moves

The mechanism is a manufacturer rebate: drugmakers pay rebates into the Medicare Supplementary Medical Insurance Trust Fund based on the gap between U.S. and international net-price benchmarks. On the provider side, CMS adjusts what Medicare pays — per the final rule, the allowed amount minus the GLOBE coinsurance amount, subject to other adjustments. In plain terms: in a GLOBE area, beginning April 1, 2027, the patient’s coinsurance on a GLOBE drug falls, and the claim must be adjudicated on that lower coinsurance figure.

The savings estimate collapsed between proposal and final. CMS now projects about $80 million a year in Part B savings and $440 million through 2034, against roughly $2.3 billion a year in the proposal. Total beneficiary savings are estimated at $111 million ($50 million in coinsurance, $61 million in premiums).

Key Insight

The smaller savings number does not shrink the billing work. A practice in a GLOBE area that infuses an in-scope oncology or rheumatology drug will see a new coinsurance calculation on its Medicare remits starting April 1, 2027, and its secondary-payer and patient statements must match. Practices outside the selected areas bill exactly as before — which is why the first task is simply to find out whether your ZIP codes are in.

The Rest of the 2027 Federal Calendar

MGMA’s September 28 federal outlook laid out what practices should plan against:

Warning

Two numbers hit on January 1: a proposed 1.68% conversion-factor cut and, in GLOBE areas, a new drug payment model. Neither is in your 2027 budget yet if you built it before September. Rebuild the Medicare line of the budget before the final fee schedule lands in November.

Section 02

Thirteen Days to Open Enrollment: Insurers Pull Out of Hundreds of Counties, 33 Health Systems Break With MA Plans — and Only 7% of Practices Say Prior Auth Got Faster This Year

On September 28, CMS released the 2027 Medicare Advantage and Part D landscape and called it stable: weighted average MA premiums are projected to fall 16.5%, from $14.37 to $12.00, and 99% of beneficiaries will have at least one MA plan. Underneath the headline, the payer mix your front desk verifies in January is moving.

5,532
MA plans for 2027, down from 5,553
344
Counties Centene is exiting, the largest pullback of any insurer
33
Health systems that have ended or are ending MA contracts in 2026
7%
Practices reporting faster prior authorization turnaround in 2026 (MGMA)

Who Is Pulling Back

InsurerCounties exited for 2027Plans removed (approx.)
Centene344~3,000
CVS / Aetna103—
UnitedHealthcare63~690
Elevance56~150
Humana—~2,400

Source: Healthcare Dive analysis of the CMS 2027 landscape, September 29. CMS projects about 34 million MA enrollees in 2027 — roughly 2 million fewer — with maximum out-of-pocket limits rising about 10% on average and Part D deductibles about 30%. That last pair matters to collections: higher out-of-pocket ceilings mean more patient responsibility on Medicare-age accounts next year.

The Network Side

At least 33 health systems have ended or are ending in-network MA contracts in 2026, several effective October 1 — two weeks before open enrollment opens October 15 (it runs through December 7). Examples include Ohio State Wexner and The James dropping Humana individual MA plans, NewYork-Presbyterian exiting most UnitedHealthcare MA plans absent a deal by September 30, and NKC Health, Valley Health, and Norman Regional leaving UnitedHealthcare. Systems cite prior authorization denials and slow payment.

A Health Affairs study published September 29 puts the brinkmanship in context: across nearly 15,000 hospital-insurer relationships from August 2021 through July 2025, only 8% of contract disputes went public, 28% of those ended in an actual network exit, and 2% of all relationships broke up.

Key Insight

For an independent practice, a hospital’s MA exit is a referral problem before it is a billing problem. If your surgeons, oncologists, or imaging partners are leaving a plan your patients are in, the downstream prior authorization and out-of-network exposure lands on your patients’ January claims.

Prior Authorization Has Not Sped Up

MGMA’s September 1 poll asked whether prior authorization turnaround improved in 2026 versus 2025: 44% said slower, 40% about the same, 7% faster, 9% unsure (178 responses). This is despite federal requirements, effective January 1, 2026, that impacted payers respond within 72 hours for expedited and seven calendar days for standard non-drug requests. 61% of practices access seven or more payer portals every week. Medicare Advantage ranked as the most burdensome payer type. Practices that did get faster cited reduced authorization lists, electronic submission tools, and internal workflow redesign.

Action Required

Before October 15, build a one-page list of the MA plans in your market that (a) are exiting your county, (b) have lost a major health system from network, or (c) are new for 2027. Give it to schedulers and patient-financial staff so patients asking “will you still take my plan?” get an accurate answer during open enrollment.

Section 03

Payers Deny Less Up Front and Claw Back More Later — While 34% of Medical Groups Have Already Built Their Own AI Tools In-House

Two data points from the last ten days frame the AI question for practices this fall. First, payers are shifting where they find money — away from front-end denials and toward post-payment recovery, the part of the cycle where automated record review scales best. Second, practices are not waiting for vendors: a third have already built their own AI tools.

34%
Medical groups that have used AI to build an app or workflow tool in-house (MGMA, September 22)
1.57%
Payer clawbacks as a share of revenue, up from 1.38% (Kodiak)
10–20%
Denial-rate reductions health systems report from AI (ISG)
20–40%
Coding productivity gains reported from AI-assisted documentation and coding (ISG)

The Payer Side Moved First

Revenue cycle leaders increasingly describe an AI “arms race”: payers ingest claims at scale, flag outlier patterns, request records, and then use AI to read those records against coverage rules and contract language. Kodiak Solutions’ first-half 2026 data (Section 05) shows the result — fewer initial denials, more clawbacks. A modifier error on a high-volume service can now trigger automated recoupment across an entire patient population, not a single denial on a single claim.

Practices Are Building, Not Just Buying

MGMA’s September 22 poll (228 responses) asked whether practices had used AI to build an app or workflow tool in-house: 34% yes, 8% tried but didn’t launch, 54% no. The tools respondents built were mostly operational: scheduling, prior authorization, dashboards, inventory, coding support, and patient intake. MGMA’s guidance before building: assess whether the tool touches patient data, map every data flow (including the AI provider), prototype on synthetic data, put ownership in writing, plan for record retention and auditability, and confirm your insurance covers homegrown tools.

Warning

A homegrown prior authorization tracker or coding helper is a business associate question, an audit-trail question, and a key-person question all at once. If the staff member who built it leaves, who maintains it? Write the owner, the data it touches, and the fallback process down before it goes into daily use.

What the Vendor Side Says It Delivers

At Becker’s IT + Revenue Cycle Conference, ISG’s healthcare lead reported health systems seeing 10–20% denial-rate reductions, 30–50% fewer manual touches, prior authorization turnaround cut from days to hours, and 20–40% coding productivity gains. Bain and KLAS research finds buyers generally want 3x or better ROI with a short time to value. R1’s new Phare UM (September 17) applies AI to flag medical-necessity denial risk while the patient is still in the hospital — part of the industry’s shift from back-end remediation to front- and mid-cycle prevention.

The Automation Stack, Early October 2026

Generative AI
Appeal letters citing contract language, record-request response packets, payer correspondence summarization, in-house tool building
AI / ML
Post-payment recoupment risk scoring, medical-necessity denial prediction, autonomous coding, underpayment detection
RPA
MA plan re-verification for 2027 changes, payer portal status checks across 7+ portals, payment posting, clawback reconciliation
Section 04

Week One on the New Code Sets: Medicare Puts Duplicate Labs on Notice, NCCI v32.3 Goes Live, and 91 Days Remain Until CPT 2027

The October 1 changeover happened yesterday. This week’s coding job is no longer readiness — it is watching the first remits and catching problems before they compound.

190
New FY 2027 ICD-10-CM codes now in effect (with 30 deleted and 4 revised)
60
New codes in Chapter 19 (injury, poisoning), the largest single increase
Mod 91
Required when a repeat lab test on the same day is medically necessary
91 days
Until CPT 2027 and the 2027 HCPCS annual update take effect

What Went Live October 1

FileWhat changedWhat to watch on remits
FY 2027 ICD-10-CM190 new, 30 deleted, 4 revised codes; largest gains in Chapters 19 (60), 15 (44) and 13 (31)Rejections for deleted codes still in favorites lists or problem lists
NCCI PTP v32.3 (practitioner and hospital outpatient)Quarterly additions, deletions, and modifier-indicator revisionsNew bundling denials on code pairs that paid in September
NCCI MUE quarterlyPractitioner, outpatient hospital, and DME unit limits revisedUnit-limit denials on injectables and therapy codes
HCPCS Level II quarterlyOctober drug and supply code changesUnlisted-drug denials where a new specific code now exists

New ICD-10-CM specificity includes dedicated codes for hereditary cancer syndromes — Lynch syndrome, familial BRCA1/BRCA2, and Li-Fraumeni — which previously shared a single “genetic susceptibility” code. Oncology, GI, and genetic counseling practices should confirm these codes are mapped in their EHR problem lists, not just the billing system.

Medicare’s October 1 Lab Reminder

The October 1 MLN Connects newsletter reminds practitioners that MACs deny duplicate lab tests that are not medically necessary — its example is a second vitamin D test — and that modifier 91 must be used when a repeat clinical diagnostic lab test on the same day is medically necessary. Modifier 91 may not be used when a test is repeated because of equipment or specimen problems, or to confirm an initial result. CMS also advises against ordering individual tests that duplicate components of a panel already ordered. Separately, MLN flagged a January 2027 update to the lab NCD edit software adding and deleting ICD-10-CM codes — a reason to re-check diagnosis pairing on your highest-volume NCD-governed labs (lipid panels, A1c, TSH, PSA) in December.

Action Required

Pull every lab claim with modifier 91 from the last 90 days and every same-day duplicate CPT without it. Duplicates without 91 are denials waiting to happen; 91s attached to a re-run for a bad specimen are an audit finding.

The Next Changeover Is Already Scheduled

CPT 2027 — including the new AI service codes and the global maternity restructure covered in September — takes effect January 1, 2027, 91 days from today. The proposed fee schedule values the G2211 complexity add-on at roughly $16 per use. Any practice that saw a spike in deleted-code or NCCI rejections this week should use that list as the test script for its January cutover.

Section 05

Initial Denials Fall to 10.63% — and 60-Day Cash Still Drops: Kodiak Data Shows Clawbacks Rising to 1.57% of Revenue as One in Three Insured Adults Carries Medical Debt

Kodiak Solutions’ first-half 2026 benchmark, drawn from revenue cycle data on 2,400 hospitals and 375,000 physicians and published September 23, contains the most counterintuitive number of the quarter: denials got better, and cash got worse.

10.63%
Initial denial rate, H1 2026 (down from 12.00%)
1.57%
Payer clawbacks as a share of revenue (up from 1.38%)
96.74%
60-day cash performance (down from 100.28%)
19.98%
Initial denial rate for private payers (down from 21.44%)

The Kodiak Numbers

Metric (H1 2026 vs. H1 2025)20252026Direction
Initial denial rate12.00%10.63%Better
Final denial write-offs (% of net revenue)3.31%3.07%Better
Payer clawbacks (% of revenue)1.38%1.57%Worse
60-day cash performance100.28%96.74%Worse
Private payer initial denial rate21.44%19.98%Better
MA initial inpatient denial rate10.75%9.15%Better
Final MA denial rate vs. Traditional Medicare—3.76% vs. 2.22%MA still 1.7x

The takeaway: a denial dashboard alone no longer measures payer friction. Money that used to be withheld at the front door is now being paid and then recouped — which shows up as negative adjustments, offsets on later remits, and A/R that looks clean but nets less.

Key Insight

Add a “net collected after recoupment” line to your monthly KPI pack. Track recoupments by payer, by CPT, and by reason code, and age them like denials. If your initial denial rate is falling and your collection rate is flat or falling, clawbacks are the first place to look.

The Patient-Side Drag

The Commonwealth Fund’s survey released September 17–18 found one in three privately insured working-age adults carrying medical debt. About half of them owe $2,000 or more; 43% attribute the debt to doctor’s office visits; 37% drained savings; 30% delayed needed care. Pair that with MA out-of-pocket maximums rising about 10% for 2027 (Section 02), and patient balances are getting larger while patients’ capacity to pay shrinks.

Where You Should Be — Cash KPIs

KPIWarning zoneTarget
Initial denial rate> 10%< 5%
Recoupments as % of paymentsNot trackedTracked monthly, < 1%
Net collection rate< 95%≥ 96%
Days in A/R> 45< 35
Point-of-service collection on known balances< 50%≥ 70%
Payment plans offered before statement 2NeverEvery balance > $500
Section 06

CMS Hires H1 for a $77.6 Million National Provider Directory as Medicare Plan Finder Starts Publishing MA Directories This Month

Bad provider data is a revenue cycle cost hiding in plain sight: wrong addresses on payer directories send patients to the wrong place, mismatched NPIs and taxonomy codes trigger credentialing and enrollment denials, and outdated network status produces out-of-network surprises. CMS is now building national infrastructure to fix it.

$77.6M
Five-year H1 contract for National Provider Directory IT development
13
Bidders competing for the award
30 days
Deadline for MA plans to update directories after a change
31
New data elements in USCDI Version 7

What Happened

On September 24, H1 Insights won a five-year, $77,635,070 contract to provide IT development for the CMS National Provider Directory (NPD), beating 12 other bidders. On September 29, CMS also selected H1 for ground-truth data sourcing and licensing, plus data aggregation, quality, and assurance services — sourcing authoritative data, normalizing and validating it, and enriching and correcting provider records.

In parallel, CMS is moving Medicare Advantage provider directories onto Medicare Plan Finder. Plans had an executive attestation deadline of September 1, 2026 for contract year 2027, production deployment begins in October 2026, and the program transitions to FHIR-based submissions in 2027. Plans must update directories within 30 days of a change, each record carries a “lastUpdatedOn” timestamp CMS uses to verify compliance, and a CEO, CFO, or COO must certify accuracy. CMS may suppress a plan’s directory from Plan Finder if validation thresholds are not met. CMS validates format and refresh — not whether a provider actually practices at a listed location.

Key Insight

Plans are on the hook, but they get their data from you. Every location, NPI, accepting-new-patients flag, and departed provider you fail to report becomes a wrong listing on a federal website patients use during open enrollment — which starts October 15.

Other Infrastructure News

Vendors in This Week’s Infrastructure News
H1Oracle HealthID.meOpenEvidenceR1 (Phare UM)
Section 07

Specialty Societies Say Insurers Lost About a Quarter of IDR Line Items by Default — as the IDR Gateway Opens and the Fee Drops to $15

On September 25, the American College of Emergency Physicians, American College of Radiology, and American Society of Anesthesiologists sent Congress an analysis of the No Surprises Act independent dispute resolution (IDR) process arguing that payer behavior — not provider abuse — drives most provider wins.

~25%
Disputed line items in 2025 that insurers lost by default
85%
Provider win rate in finalized federal payment determinations
8.2%
Line items where the payer’s offer was $1 or less
$15
Reduced per-party IDR administrative fee (from $115)

What the Analysis Says

FindingFigure
Line items insurers lost by default (2025)~25%
Line items with payer offers at or below the QPA (excluding defaults)Nearly 40%
Line items with payer offers of $1 or less8.2%
Provider win rate in finalized determinations85%
Typical award vs. QPA2.5x–4x

Critics point to a Georgetown estimate of $22 billion in additional costs from the IDR system over four years. The societies’ reply is that payers who skip participation or submit nominal offers are choosing to lose.

The Operational Changes

Action Required

If your practice bills out-of-network emergency, anesthesia, radiology, or other NSA-protected services, register on the IDR Gateway now, track every award’s 30-day payment deadline, and log unpaid awards by payer. The documentation is your leverage in any complaint or future enforcement action.

Also on the Calendar

Medicare Plan Finder’s MA directory publication (Section 06) makes directory accuracy a compliance item for practices, too: an inaccurate listing that sends a patient to an out-of-network location can become a surprise-billing dispute.

Section 08

At MGMA’s 100th Conference, 97% Report Higher Operating Costs and 89% Rank Reimbursement a Top-Three Worry

Black Book Research surveyed attendees at the MGMA Annual Conference in San Antonio (September 27–30) — a quarter of them CFOs, finance directors, and revenue cycle leaders, and a fifth physician owners and medical directors. The results, released September 29, describe practices heading into 2027 under pressure from every direction at once.

97%
Report higher year-to-date operating costs than at this point in 2025
90%
Rank patient coverage, affordability, and continuity among top-three concerns
89%
Rank reimbursement and financial sustainability among top-three concerns
87%
Rank IT performance and technology-enabled administrative relief among top-three concerns

A Decade of the Same Answer

MGMA marked ten years of its weekly Stat poll on September 29 — more than 380,000 responses. The trend lines independent practices will recognize: the share saying prior authorization requirements increased ran 82% in 2016 and 90% by 2019 and has stayed high; 84% in 2026 say costs are outpacing revenue (after 92% in 2024); most groups have gone years without a commercial payer rate increase; and MGMA’s federal outlook found 90% of practices report patients shifting to MA and 79% report negative effects from it.

How This Week Lands on a Small Practice

Where You Should Be — Independent Practice Benchmarks

MetricWhere most independents areWhere you should be
Initial denial rate10–14%< 5%
Recoupments tracked by payer and reasonNot trackedMonthly
Days in A/R42–50< 35
Payer portals worked weekly7+ (61% of practices)Consolidated through a clearinghouse or RPA
Commercial contracts reviewed for rate escalatorsYears since last increaseEvery contract reviewed annually
2027 budget reflects the proposed CF cutNot modeledModeled at −1.68%
In-house AI tools with a named owner and fallbackUndocumentedWritten owner, data map, fallback
MA plan list for open enrollmentNoneDistributed to front desk by October 15
What to Prioritize Next

(1) Model the 1.68% conversion-factor cut against 2027 Medicare revenue; (2) add a recoupment line to the monthly KPI pack; (3) send a rate-increase request to every commercial payer whose contract has not moved in two years; (4) document every in-house AI tool’s owner and data flow; (5) publish an MA plan cheat sheet for open enrollment.

Section 09

Oncology, Rheumatology and Ophthalmology Enter GLOBE, Cardiac CT Loses Up to 68% in Real Terms, and Orthopedics Watches 637 More Procedures Leave the Inpatient-Only List

This week’s specialty picture is driven by the GLOBE final rule, the October 1 code sets, and the proposed 2027 fee schedule — landing unevenly across service lines.

SpecialtyThis week’s updateData pointPriority action
Primary CareProposed 2027 CF cut; G2211 add-on valued around $16; new-patient waits longer at 28% of groups; Medicaid work requirements start by January 1−1.68% proposed CFModel 2027 Medicare revenue; prepare front desk for Medicaid eligibility churn in January
CardiologyJournal of Cardiovascular CT study (September 30): inflation-adjusted Medicare pay for cardiac CT fell 27–68% from 2010 to 2026 while CCTA volume rose 408% (2013–2024)CCTA −68.3% realRe-check CCTA cost per study against payment before 2027 volume planning
OrthopedicsYear two of three of CMS’s inpatient-only list phase-out; EBRI site-neutral analysis renews ASC vs. HOPD debate637 procedures leaving IPO listConfirm site-of-service and prior auth rules per payer for newly eligible outpatient cases
OncologyGLOBE finalized: in-scope Part B oncology drugs in selected areas get international benchmark rebates; coinsurance falls April 1, 202725% of Original Medicare in GLOBE areasConfirm whether your ZIP codes are in GLOBE; flag in-scope drugs in the charge master
Rheumatology / ImmunologyHigh-spend biologics without biosimilar competition fall within GLOBE scope>$100M Medicare spend thresholdList infused biologics that cross the threshold; plan for new coinsurance math
OphthalmologySingle-source intravitreal drugs above the spend threshold fall within GLOBE scope5 therapeutic classes in GLOBEUpdate patient estimates for April 1, 2027 coinsurance changes
RadiologyACR co-signed the IDR analysis; 85% provider win rate in finalized determinations~25% of line items lost by payer defaultRegister on the IDR Gateway; track 30-day award payment deadlines
Mental / Behavioral HealthMedicare telehealth flexibilities run through December 31, 2027; psychotherapy codes are shielded from the 2.5% efficiency adjustment0% efficiency cut on psychotherapyKeep POS 10 and audio-only modifiers clean; plan 2028 in-person capacity
GastroenterologyNew ICD-10-CM codes for Lynch syndrome now in effect; endoscopy codes remain under the 2.5% efficiency adjustmentDedicated Lynch syndrome code live October 1Update surveillance colonoscopy diagnosis mapping for hereditary risk
Pathology / LabMLN reminder: duplicate tests denied unless medically necessary; modifier 91 for valid same-day repeatsLab NCD edits update January 2027Audit modifier 91 use; check panel/component duplication
Key Insight

GLOBE is the first mandatory payment model to touch infusion revenue directly, and it lands on the same practices — community oncology, rheumatology, retina — that already carry the largest buy-and-bill exposure. The billing change is a coinsurance change, but the cash risk is patient collections: a lower coinsurance figure on the Medicare remit that does not match the estimate, the secondary claim, or the statement creates rework on every infusion visit.

Section 10

This Week’s Action Items

Ten moves for the week of October 2, 2026 — each tied directly to something in this issue.

7%
The share of medical practices that say prior authorization got faster in 2026. Nine months after federal rules required impacted payers to answer standard requests within seven days and expedited requests within 72 hours, MGMA’s September poll found 44% of practices saying turnaround got slower, 40% saying nothing changed, and just 7% reporting improvement. Over the same period, payers cut initial denials to 10.63% while lifting clawbacks to 1.57% of revenue, 33 health systems walked away from MA contracts over authorization and slow payment, and 97% of practices at MGMA’s 100th conference reported higher operating costs. Rules on paper have not reached the front desk. Until they do, the practices that win are the ones measuring their own turnaround, their own recoupments, and their own portal hours — and taking those numbers to every payer contract negotiation.