Downcoded

The Downcode Record: Three Rate Books and Thirty-One Days

Three of the four CY 2027 Medicare rate books are still inside OMB this morning, and without a waiver finding the last date one can publish and still bite on January 1 is December 2. The one that got out, dialysis, took 41 days and came in $2.03 under its own proposal. Home health hits 41 days today.


Fourteen CMS regulatory actions are sitting inside OMB this morning, out of 164 pending across the whole government.

Three of them are the rate books that start paying your claims on January 1.

The outpatient rule has been in there 45 days. Home health, 41. The physician fee schedule, 33.

All three are flagged Legal Deadline: Statutory, and none is on the Federal Register's public inspection desk this morning.

A fourth went in with them and came out last week. The dialysis rule took 41 days at OMB, published October 30, and landed $2.03 below the base rate CMS proposed in June.

So the record's finished half picked up $240 million in October. The unfinished half, the one with $5.7 billion of 340B money in it, did not move at all (chart below).

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.