Medicare Has Made Its Own Rate Book Deadline Once in Eight Years
Four CY2027 rate books sit at OMB this morning, all four flagged with a statutory deadline, none of them on public inspection. The statute behind the physician fee schedule says before November 1, which leaves five business days counting today. We pulled the filing instant off eight years of Federal Register public inspection copies: CMS has cleared that line once, at 5:10pm on a Friday with under seven hours to spare. Also in the window: a coverage database that is eight days behind its own data, and four MAC pain policies that went live inside the gap.
Four Medicare rate books sat at the Office of Management and Budget this morning. Every one of them carries the same three words in the OIRA record: Legal Deadline: Statutory.
None is on public inspection at the Federal Register. We checked the current list at 9:22 UTC: 107 documents, 16 of them rulemakings, and the only HHS rulemaking among them is the Exchange verification proposal filed Friday the 23rd.
The physician fee schedule is the one with a date attached. Section 1848(b)(1) of the Act says the Secretary shall establish the fee schedules before November 1 of the preceding year.
Today is the 26th, and November 1 is a Sunday.
So the rule has five business days to appear, counting today.
"How close does Medicare normally cut it on the rate book?"
One for Eight
Closer than anyone who has not measured it would guess.
Every Federal Register document keeps its public inspection copy on a static
URL, and that file's Last-Modified header is the instant it went up. Pull it
for the fee schedule final rule back through CY2019 and the filing record comes
out to the minute (chart above).
CMS has cleared November 1 once in eight rate years. That was last year's rule, filed at 5:10pm ET on Friday, October 31, 2025, with 6 hours and 50 minutes left on the clock.
The rest of this brief is for subscribers.
The impact tables, the code-level detail, and the rest of the analysis sit past this line.
$50 a month, or $500 a year.
Already a subscriber? Sign in