CMS proposed a $260M imaging cut for CY 2027. It only works because two characters on a claim line, modifier PO, reliably identify the target setting. That is interoperability doing real work.
The cut applies only to noncontrast imaging in APCs 5521-5524 at grandfathered off-campus departments billing PO. Rural sole-community hospitals are exempt. On-campus departments are not touched. Scope matters.
The utilization case: volume up 38% and utilization per FFS beneficiary up 67% from 2016-2025, while FFS enrollment fell 17%. CMS pegs 2027 savings at $260M and $8.5B over a decade.
The price transparency side of the package is on the same logic. CMS solved file parsing. The 2027 RFI goes after contract meaning: stop-loss clauses, rate tiers, payer identifiers that actually match across hospitals.
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