Part II: Sometimes Interoperability Is Just a Modifier: CMS’s CY 2027 Imaging Site-Neutral Cut, the Hospital Machine-Readable File, 835 Allowed-Amount Percentiles, and the Contract-Semantics Price

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-cam…