2027 Readiness: What's Final and What's Still Proposed

Welcome! Here is the clearest way I can say this as a physician executive and physician consultant: waiting for every rule to be finalized before beginning the work means everything lands at once, at the end. You do not need a final rule to start the work that does not depend on it.

That is the contrarian point, and in October 2026 it matters.

It is easy to treat all 2027 change the same way — as if every item is either settled or uncertain together. It is not. Some parts of your 2027 readiness plan are already final, already effective, and already actionable. Other parts are still proposed, which means you should model, watch, and prepare without treating them as requirements.

190

That number alone should get your attention. CMS finalized 190 new ICD-10-CM codes for FY 2027, effective October 1, 2026 through September 30, 2027. Whether or not your practice is also watching the Medicare Physician Fee Schedule, ICD-10 readiness is not optional. It is already here.

Final versus proposed: the distinction your practice needs right now

If you only remember one thing from this article, let it be this: final and proposed are not just regulatory labels. They tell you how to prioritize work.

When something is final, your team should be implementing, educating, testing, and monitoring.

When something is proposed, your team should be modeling scenarios, identifying risk points, and avoiding overreaction until CMS publishes the final rule.

Two common missteps:

• ignore proposed changes until the last minute, or
• treat proposed changes as if they are already mandatory.

Both create operational problems.

I would rather see your practice split the work cleanly:

1. Do now what is already final or what will be necessary regardless of the final rule.
2. Model now what is still proposed.
3. Decide fast later when the final rule arrives.

That is how physician-led readiness works.

What is already final or already decided

1) FY 2027 ICD-10-CM is final and in effect

The FY 2027 ICD-10-CM updates are effective for encounters and discharges from October 1, 2026 through September 30, 2027. CMS finalized:

• 190 new codes
• 30 deletions
• 4 revisions

The updated official guidelines also include revisions touching:

• sepsis
• cancer treatment
• hypertension
• genetic disorders
• DES exposure

This is not a “wait and see” issue. Your diagnosis coding, claim edits, charge capture logic, and education plans should already reflect the FY 2027 update. If your coders know the code file changed but your templates, pick lists, and physician habits did not, you are setting up avoidable friction.

2) CPT 2027 is final, and the maternity changes are the headline issue

The AMA announced the release of the CPT 2027 code set on September 9, 2026, with an effective date of January 1, 2027.

The headline change is the maternity care restructure. The traditional global obstetric package is being replaced by phase-based reporting across:

• antepartum care
• labor management
• delivery
• postpartum care

Within the maternity section, the totals are:

• 12 new codes
• 17 deleted codes
• 6 revised codes

The AMA released these maternity changes early to help physicians, payers, and EHR vendors implement in time.

Here is the important framing: for OB/GYN, this is a structural overhaul. For every other specialty, this is still a normal annual CPT year plus standard preparation.

That distinction matters, because CPT 2027 is not a system-wide coding emergency. If you are not in women’s health, this should still be a disciplined annual code-set transition — important, yes, but not a reason to destabilize your entire workflow.

If you want additional context, read CPT 2027 is coming.

3) Medicare telehealth flexibilities are final through December 31, 2027

The Consolidated Appropriations Act, 2026, signed February 3, 2026, extended Medicare telehealth flexibilities through December 31, 2027.

This is final.

It is also important to say what it is not: this is a legislative extension, not a new CPT code set. Practices should avoid blending telehealth policy extensions together with annual CPT code updates as if they are one issue. They are not. Operationally they may intersect, but legally and administratively they come from different places.

4) CMS-0057-F prior authorization requirements are final

Under CMS-0057-F, impacted payers must implement a Prior Authorization API by January 1, 2027. In addition, since 2026 they must provide a specific reason for every denied prior authorization request regardless of submission method.

This was finalized January 17, 2024. So again, this is not speculative. It is not on the rumor list. It is final.

Practices should be using this period to improve authorization workflow design, denial tracking, and escalation patterns. If your team is still documenting prior auth denials in free-text email chains with no structured reason categorization, you are missing an opportunity to build a much smarter front-end process.

5) OIG General Compliance Program Guidance is final and applicable now

The HHS-OIG General Compliance Program Guidance from November 2023 is final guidance and remains highly relevant now. The seven elements of an effective compliance program are not new, but they continue to be the backbone of a credible compliance structure.

If your compliance plan is sitting on a shared drive untouched since before your current AI documentation workflows, telehealth patterns, or payer edit environment changed, then your document may exist — but your program is outdated.

This is a good time to refresh:

• written policies and procedures
• education and training
• lines of communication
• internal monitoring and auditing
• enforcement and accountability
• response and corrective action
• compliance leadership and oversight

6) ONC HTI-1 is final, and the clock is already running

The HTI-1 final rule from ONC includes the Decision Support Interventions certification criterion and the Insights Condition.

The timing is what is easy to miss. Year 1 data collection begins in calendar year 2026, and the first reports are due in July 2027.

That means this is not a distant IT issue for someone else to handle eventually. If your organization uses certified health IT with decision support functionality, governance, documentation, measurement, and cross-functional oversight should already be on your radar.

Especially if your workflows include AI-assisted documentation or other technology-enabled support tools, you need visibility into how outputs are being used, monitored, and explained. Documentation and technology governance is a compliance and operations responsibility, not only a software one.

What is still in motion: the CY 2027 Medicare Physician Fee Schedule proposed rule

Now let’s talk about what is not final.

The CY 2027 Medicare Physician Fee Schedule proposed rule, released July 14, 2026, is still a proposal. A final rule is expected around November 1, 2026, and the public comment period closed September 14, 2026.

As of early October 2026, do not present any CY 2027 PFS provision as a requirement, a deadline, or a certainty.

That includes:

• the proposed conversion factor of approximately $33.17 for qualifying APM participants
• the proposed conversion factor of approximately $32.84 for non-qualifying participants
• the proposed same-day E/M plus procedure payment reduction
• the proposed G2211 restructuring

These may change. Some may be finalized differently. Some may be revised in implementation detail. Your job right now is not to panic. Your job is to prepare intelligently.

This is where a proposed rule is easily mistaken for a decided one: a proposed PFS summary gets read, and providers start getting trained as though CMS has already made the decision. That creates confusion, rework, and credibility problems for leadership.

I recommend a different approach:

• treat the proposal as a planning model
• identify where revenue, workflow, and documentation could be affected
• estimate operational exposure under multiple scenarios
• hold final training language until the final rule is issued

That is a much steadier posture.

If your practice needs a grounding point on documentation fundamentals while waiting for final payment policy, the underlying E/M habits remain valuable regardless of late-year payment-rule noise.

A practical readiness framework: what you can do now no matter what CMS does later

This is where disciplined preparation separates itself. You do not need to know every final PFS detail to begin the readiness work that will help you either way.

1) Code and charge mapping against the new code sets

Start with what is settled:

• map FY 2027 ICD-10-CM changes into diagnosis workflows
• map CPT 2027 updates into charge capture logic
• identify deleted, revised, and replacement patterns
• review edit dependencies in billing software, scrubbers, and interfaces

For OB/GYN, this means focused mapping around the maternity restructure. For everyone else, this means your normal annual CPT review should still happen on time and in full.

2) EHR template and preference list work

This is worth starting early.

Picture two practices. One begins template work in October, tests preference lists in November, and enters January with manageable cleanup. The other waits until December, rushes build requests, and spends the first weeks of January asking physicians to work around incomplete tools.

Same physicians. Same EHR. Very different experience.

Your team can start now on:

• diagnosis pick lists
• charge tickets
• order sets where relevant
• favorites and preference lists
• specialty templates
• maternity documentation workflows if applicable

None of that requires a final CY 2027 PFS rule to begin.

3) Payer contract and fee schedule modeling

You do not need to assume the proposed conversion factors will become final in order to model them.

Build at least two scenarios:

• current-state payment assumptions
• proposed-rule payment assumptions

If you have enough internal analytics support, a third blended scenario can help as well. The point is not to predict perfectly. The point is to understand sensitivity:

• which service lines would feel pressure
• where same-day visit-and-procedure patterns may matter
• how payer contract language references Medicare or internal fee schedules
• where documentation and charge capture discipline become more important

This is also a good time to review payer policy variation. Medicare proposals can prompt commercial payer attention, and payers do not necessarily follow at the same pace or in the same way.

4) Provider and coder education calendar

Do not save education for the week between Christmas and New Year’s.

Build a calendar now:

• October: coding leadership and operational review
• November: final-rule update session once published
• December: provider specialty education and simulation
• January: first-live monitoring and rapid feedback

For maternity services, education should be deeper and role-specific because the reporting model is structurally different. For other specialties, this may look more like your standard annual update cycle.

5) Documentation standards for the new maternity phases

If your organization bills obstetric care, this deserves its own workstream.

The move from the traditional global package structure to phase-based reporting affects:

• documentation architecture
• charge triggers
• scheduling coordination
• handoff clarity
• payer communication
• physician and staff education

This is not just a coding memo. It is a workflow redesign issue. Your documentation standards need to support clean distinction across antepartum care, labor management, delivery, and postpartum care.

That work should already be underway if OB/GYN is part of your practice.

6) Authorization workflow build for CMS-0057-F

Because CMS-0057-F is final, your readiness work can be specific.

Review:

• how denial reasons are captured
• who owns follow-up
• whether patterns are trended by payer, service, and diagnosis
• whether your EHR or revenue cycle tools can structure those reasons for reporting
• how your team will interact with payer API-enabled workflows where applicable

This is also a strong time to tighten your appeal documentation discipline, because a well-organized appeal file is what carries a challenge through.

7) Compliance program refresh

Your readiness plan should include a real compliance refresh, not just an annual checkbox.

That means reviewing:

• policy alignment with current workflows
• audit priorities for 2027 risk areas
• escalation pathways
• documentation governance
• oversight of technology-enabled documentation tools
• education logs and accountability structures

The practices that move through annual change with the least disruption are not the ones with the flashiest dashboards. They are the ones with the clearest compliance structure and the fastest communication loops.

Your Q4 timeline: October, November, December, January 1

Here is the practical timeline I would use.

October

• implement FY 2027 ICD-10-CM changes
• complete CPT 2027 impact review by specialty
• identify whether maternity restructuring applies to your organization
• begin EHR template, charge, and pick-list updates
• begin payer modeling using current and proposed assumptions
• refresh compliance plan priorities
• review prior authorization workflows for CMS-0057-F readiness

November

• review the final CY 2027 PFS rule once released
• compare the final rule against your proposed-rule model
• update internal assumptions only where the final rule requires it
• finalize payer and service-line financial modeling
• confirm EHR build and testing status
• finalize training content for coders, billers, and providers

December

• complete end-user training
• run testing for charge capture, edits, and claims
• finalize OB/GYN maternity workflow steps if applicable
• communicate payer-specific operational changes
• confirm monitoring plans for the first weeks of January
• verify that leadership, coding, billing, compliance, and IT are aligned

January 1

• go live with CPT 2027 workflows
• monitor denials, holds, edit failures, and documentation gaps daily
• escalate quickly when a build issue, payer mismatch, or training gap appears
• avoid broad policy changes based on assumptions that were never finalized

The goal is not perfection on day one. The goal is controlled execution.

My closing rule

Do not wait for every rule to be final before you prepare; separate what is decided from what is still proposed, and start the work that helps you either way.

If you want support with physician-led revenue integrity, documentation strategy, payer-readiness planning, or 2027 implementation review, you can schedule a consultation with DSKC here: Dr. Sloan-Kelly Consulting consultation.

Thank you for reading and for doing the hard work of leading through change with clarity.

Dr. Dreama Sloan-Kelly, MD, CCS, CPC / CEO/President, Dr. Sloan-Kelly Consulting LLC

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Sources

1. AMA CPT 2027 maternity care code changes
2. AMA CPT 2027 code set announcement, September 9, 2026
3. CMS ICD-10-CM code sets
4. CDC/NCHS FY 2027 ICD-10-CM Official Guidelines for Coding and Reporting
5. CMS CY 2027 Medicare Physician Fee Schedule proposed rule fact sheet
6. CMS-0057-F Interoperability and Prior Authorization final rule
7. HHS-OIG General Compliance Program Guidance, November 2023
8. ONC HTI-1 final rule