How Your Conversion Factor Drops Without Anybody Cutting It
All three overdue CY 2027 Medicare rate books filed for public inspection at 5:00 p.m. Wednesday, 4,185 pages under one timestamp. The fee schedule contains no rate cut and the conversion factor still falls 2.31 percent, because the 2.50 percent Congress bolted on for 2026 expires and the update replacing it is ten times smaller. Outpatient landed 340B on ASP minus 28 percent, the alternative CMS passed over in July.
Three documents went onto the Federal Register's public inspection desk at 5:00 p.m. Eastern on Wednesday, all three stamped with the same filing minute.
The physician fee schedule, 2,468 pages. Outpatient and ASC, 1,270. Home health, 447.
That is 4,185 pages of CY 2027 rate book filed in one minute, three days after the fee schedule's statutory deadline passed. Outpatient publishes November 6 and the other two November 9, which clears December 2, the last publication date we put on a rule that still bites on January 1, with more than three weeks to spare.
All three are off OMB's pending list this morning. On Tuesday we charted them sitting there at 47 days for outpatient, 43 for home health and 35 for the fee schedule.
"If nothing in the fee schedule cuts the conversion factor, why does it fall 2.31 percent?"
The Cut Nobody Made
Read CMS-1848-F front to back and no policy in it reduces the conversion factor.
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