CY 2027 proposed rule
What the Medicare PFS changes, specialty by specialty.
Fulcrum reconstructs the payment build-up behind the national estimates, then traces the proposed policies to the services and codes that move.
CMS-1848-P was released July 14, 2026. Comments close September 14, 2026.
View the CMS rulePublished analysis
Begin with the evidence behind the specialty estimate.
Each analysis separates the national headline from the policy mechanics, service categories, and code-level changes that create it.

Why the proposed impact is not evenly distributed.
CMS estimate -9.4% ยท Fulcrum reconstruction -9.9%
Read the full analysis โMethodology
Specialty estimates are context. Utilization creates the forecast.
Fulcrum holds CMS's 2025 utilization basis constant, reconstructs the proposed Medicare payment build-up, and isolates the policies and codes driving each specialty result. A practice forecast goes further by applying those changes to the organization's actual CPT mix, locality, sites of service, and Medicare-linked contracts.
Read the full methodology โYour practice
See where your own service mix lands.
Send a CPT utilization file after a BAA is signed. Fulcrum returns a practice-specific PFS forecast within 72 hours.
Contact us