Medicare Gives Clinical AI a Billing Identity Before It Has a Price Theory: The CY 2027 OPPS SaMS Proposal, the New O1 Status Indicator, the New Technology Bridge, and the Lab-Analysis

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Medicare Gives Clinical AI a Billing Identity Before It Has a Price Theory: The CY 2027 OPPS SaMS Proposal, the New O1 Status Indicator, the New Technology Bridge, and the Lab-Analysis

Jul 22, 2026

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Medicare just gave clinical AI a billing identity. It has not given it a price theory. That gap is the whole story in the 2027 OPPS proposed rule.

CMS is retiring Software as a Service and replacing it with Software as a Medical Service (SaMS). Not cosmetic. It’s CMS trying to reframe these as clinical services, not subscriptions. Matters a lot once you …

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