The CY 2027 outpatient and Physician Fee Schedule final rules are expected in early November 2026. Two proposals inside them decide a great deal for health technology companies.
The first established a Medicare payment category called Software as a Medical Service. It designates 36 HCPCS codes, creates a dedicated payment status indicator for separately payable software services, and proposes moving ten algorithm-only laboratory analyses off the Clinical Laboratory Fee Schedule on the reasoning that once the lab work is complete, downstream computation does not require a CLIA-certified laboratory.
The unresolved question is whether the new status indicator escapes multiple-procedure discounting. If it does, the economics work. If it does not, the software takes a reduction every time it runs alongside another procedure. CMS solicited comment on precisely that point, which is a reasonable signal that the agency has not settled it.
The second proposal would make remote physiologic and remote therapeutic monitoring payable only when furnished by clinical staff who are direct employees of the billing practice. That would end a common vendor arrangement in its current form.
The comment windows closed on August 31 and September 14, 2026, so influence is no longer available. What is available is preparation.
Model both outcomes now. A company that already knows which scenario it is in will be able to move in November. The rest will spend the month reading.