The Rate Update That Shipped Without the Rates

CMS sent MACs the FY 2027 hospice payment instruction in July with the payment tables missing, and replaced it on August 18 to put them back. Two more transmittals were rewritten the same week under change request numbers that never changed, one of them quietly adding a place-of-service rejection edit to a CR whose summary still says no policy is being changed.

Change request 14557 carries everything a MAC needs to pay a hospice claim on October 1. It went out on July 16 without the rates.

CMS said so itself yesterday, in the transmittal that replaced it: Transmittal 13872 is rescinded and replaced by Transmittal 13924 to include "the FY 2027 payment tables (tables 1 and 2) and the FY 2027 wage index transition code table (table 3) that were previously omitted in the earlier version."

The change request number is the same. The effective date is the same. The document is four pages longer.

"How do you diff a policy change against itself when the identifier never moves?"

That is not one clerical miss. Three of the transmittals CMS issued between August 14 and August 18 rescind and replace instructions already sitting in the record, and the gap between the version providers read and the version that binds the claim runs as long as 80 days (chart below).

The rest of this brief is for subscribers.