The FY 2028 code set is being decided right now

• Spring 2027 · CMS ICD-10 Coordination and Maintenance Committee meetings. The FY 2028 code set gets shaped here. [Confirm dates on the CMS site.]
• April 1, 2027 · Next quarterly NCCI PTP update takes effect.
• Oct 1, 2027 · CMS has proposed compliance dates beginning here for electronic prior authorization for drugs. Proposal only.
• Dec 31, 2027 · Medicare telehealth flexibilities expire, absent Congressional action.
• Through CY 2027 · MIPS electronic prior authorization attestation period runs.

Where October comes from

Every year your team absorbs a code set someone else decided. Most coding operations meet those codes in June when the addenda post, or in September when the panic starts. The decisions were made in spring, in public, at meetings anybody can attend.

The CMS ICD-10 Coordination and Maintenance Committee takes proposals, discusses them openly, and accepts written comments. That is how the QA1 hereditary cancer codes happened: Fight CRC and CGA-IGC members ran a campaign, asked for five gene-specific Lynch syndrome codes, and got one. They did not get everything they wanted. They got a code that did not exist before, which is more than most organizations ever attempt.

Two things follow for your operation.

You can read October in March. Proposals discussed in spring are the shortlist for the following October. A coding manager who reads them has six months of warning instead of six weeks, and knows which of their specialties will be affected before the addenda drop.

You can ask. If your organization codes a condition that has no good code, that is a proposal somebody could submit. Clinical societies do this every year. Provider organizations almost never do, which is why the code set reflects specialist priorities more than operational ones.

How to actually do this

Assign it to one person for two days a year. Their job is to read the spring agenda, flag every proposal touching your top five specialties, and write a one-page note on what would change if each passed.

That note does two things. It gives you a head start on configuration, and it tells you whether a comment is worth submitting. Both beat discovering a code change in an October rejection.

The telehealth cliff is ten months out, which means it is now

Medicare telehealth flexibilities expire December 31, 2027. The geographic and originating-site waivers, along with FQHC and RHC distant-site billing, all run to that date. Behavioral health telehealth is permanent and unaffected. Audio-only coverage and the tele-mental health in-person delay carry different end dates depending on the source, so confirm those against the statute rather than trade coverage.

Congress has extended these flexibilities several times, and may again. Planning on that is a decision rather than a default, so make it one.

Three questions worth answering in Q1 rather than Q4:

• What share of your volume depends on the geographic and originating-site waivers? For some practices this is a rounding error. For others it is the practice.
• Which of your telehealth services survive the cliff on their own? Behavioral health does. Work out what else does.
• If the waivers lapse, what happens to your coders' workload mix? Telehealth encounters and in-person encounters do not document alike, and a shift in the ratio changes your routing.

The teams that handled the 2020 to 2026 extension cycle well all did the same thing: they modeled the lapse once, early, and then stopped re-litigating it every quarter.

Re-baseline now, with a full quarter of 2027 data

You have one quarter of claims under CY 2027 rates, NCCI v33.0 and the new telehealth modifiers. That is enough to reset three numbers you carried over from 2026.

Denial rate. Expect it to look worse than Q4 and not to mean much. A quarter containing a four-change convergence is not a baseline.

Takeback rate as a share of accounts receivable. This one is a baseline, because takebacks reflect claims paid months ago. If you started measuring it in January as recommended, you now have your first real quarter. The industry moved from 1.38% to 1.57% across the first half of 2026.

Appeal recovery rate. Industry recovery fell to 2.21% of accounts receivable from 2.48%. Check yours against the appeal thresholds you set, and against a conversion factor that went down rather than up. Some denials you have always chased stopped being worth chasing.

The spring question

Q1 is when most RCM and billing companies find out whether their capacity plan survives contact with new business. The contracts signed in January arrive as volume in March, and the hiring started in January does not.

AAPC's 2026 salary report puts certified medical records specialists at $67,260 against $55,721 for non-certified, with stacked credentials reaching $81,227 at three or more certifications. Budget solves none of this. A credentialed coder with the right specialty experience takes months to recruit, and your March volume was promised in January.

So the question that decides your spring is the same one that decided your January: what share of your certified coders' hours went to charts that never needed certified judgment.

CODIO AI routes per chart. Complete charts flow through AutoPilot for fully autonomous coding. Thin or contradictory documentation stays in CoPilot, where certified coders review and finalize. Teams see 45% more output per coder, measured against a manual baseline: same team, same charts, before and after, and MediCodio AI reports cutting coding costs by up to 60–70%. Adding a specialty is configuration rather than another vendor, across 35+ specialties in production today.

Nothing runs autonomous on day one. The lane widens only as accuracy is proven on your charts by your auditors, one specialty or case type at a time.

• [Article 1]
• [Article 2]
• [Article 3]

Since switching to MediCodio, my office has had more time to focus on collections and patient billing. Our coding is so streamlined, I don't even have to think about it. — Chris McMenemy, Ortmann Healthcare Consulting Services