Six separate Medicare and Medicaid changes take effect on January 1, 2027.
The FHIR-based prior authorization API requirement. The Software as a Medical Service payment framework, if finalized. The remote physiologic and remote therapeutic monitoring staffing restriction, if finalized. New telehealth modifiers that make platform-affiliated arrangements visible in Medicare claims data for the first time. Medicaid work requirements across all 41 expansion states plus the District of Columbia. And a retroactive Medicaid coverage window that shrinks from three months to one month for adults aged 19 to 64.
Read individually, each is a compliance item. Read together, they are a convergence.
Two consequences follow. First, a buyer’s attention for the remainder of this quarter is going to be consumed by January readiness. That either makes a vendor urgent or makes a vendor invisible, with very little middle ground between the two. Second, the comment windows on the proposed rules closed in August and September. The influence stage is over, and the final rules are expected in early November.
What remains is roughly twelve weeks. Know which of the six changes touches your product, and be able to state it in a single sentence.
IronStreet covered each of these developments as it happened, in the June and August 2026 issues of The Signal.