AI · Reimbursement
Paying for AI is still being written.
Medicare is actively working out how to reflect the cost of AI and Software-as-a-Service tools — issuing requests for information, adding new code families, and building the pathways that will decide how software-enabled care gets paid.
CY2026 Physician Fee Schedule
What the CY2026 rule settled.
Finalized in late 2025 and effective January 1, 2026, the CY2026 Medicare PFS is CMS's clearest statement yet on how AI and SaaS will be valued — and the CY2027 proposed rule (July 2026) picks up where it left off.
On CMS's agenda
- AI & SaaS costs — CMS gathered industry input on reflecting AI and Software-as-a-Service costs — still unresolved, and back on the table for CY2027.
- MIPS AI patient safety — a new Patient Safety and Practice Assessment activity to build data collection on AI-attributable events and near misses.
- Diabetes Prevention Program — online sessions must keep live coach interaction; AI and machine learning may not replace live coaches.
Open Questions
Where CMS is asking for input
Cost Incorporation
CMS wants feedback on how to pay for SaaS — risk-based payment arrangements, alternative pricing strategies, valuing physician work, data sources for costs, use in chronic disease, and evaluating quality and efficacy.
Efficiency Adjustments
CY2026 finalized a -2.5% efficiency adjustment to work RVUs for non-time-based services. Still open: which codes should accrue efficiencies over time — and does AI create efficiencies current valuation doesn't capture?
Tech-Assisted ASD Diagnosis
CMS weighed a new add-on G code for FDA-authorized eye-tracking technology aiding Autism Spectrum Disorder (ASD) diagnosis in pediatric patients — not finalized for 2026; comments feed future rulemaking.
The Code Families
How software-enabled care is starting to get codes
Category III — AI-Augmented Services
Seven new Category III (temporary tracking) CPT codes were added in 2025 for AI-augmented services across chest imaging, cardiology, and urology.
Digital Mental Health Treatment Devices
HCPCS codes (proposed as GMBT1–3, finalized as G0552–G0554) create a reimbursement pathway for FDA-cleared digital mental health treatment (DMHT) devices used alongside an ongoing behavioral therapy plan.
DMHT Devices for ADHD
The CY2026 final rule extends DMHT device payment to FDA-cleared devices supporting ADHD therapy.
The codes are still being written.
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