Downcoded

Why the Dialysis Rule Left OMB Before the Fee Schedule

One of the four CY2027 Medicare rate books has dropped off OMB's pending review list, and it is the only one of the four whose statute names no publication date. The physician fee schedule, which does, is still inside on day 29 with two business days to beat it. Also in the window: Aetna's November bulletin surfaced after five weeks of 404s and puts eleven things on the precertification list while taking none off, two of them effective Sunday.


A rule leaves the Office of Management and Budget the same way it arrives, with no announcement. The only way to watch it happen is to count what is still there.

So we counted. The pending Executive Order 12866 review list this morning holds 167 reviews government-wide, 13 of them CMS.

Three weeks ago that set held all four CY2027 Medicare payment final rules.

Today it holds three.

"Which rate book got out, and was it the one on the clock?"

One Left, and It Was the Loose One

0938-AV81 is gone.

That RIN belongs to the End-Stage Renal Disease prospective payment system final rule, CMS-1846, and it ties cleanly to the Federal Register's own record of the proposed version published June 26 at 91 FR 38784. OIRA received it on September 17, the same day it received the outpatient rule.

The other three are all still carrying Status: Pending Review: outpatient and ASC (0938-AV83) on day 41, home health (0938-AV80) on day 37, and the physician fee schedule (0938-AV82) on day 29 (chart above).

Nothing has surfaced at the far end either. The Federal Register's public inspection list carried 105 documents at 9:31 UTC with not one from a Medicare agency, and the CMS docket has published nothing of any kind since October 21.

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.