74 days to Jan 1: 4 Medicare calls for PTs

Today is 19 October 2026. There are 74 days before the first Medicare payment changes for 2027 would start on 1 January (HFMA, July 2026), and the final rule that confirms them is not due until some point in November (Medical Economics, September 2026). That leaves 13 days before November begins and, at best, about six weeks between the final rule and the first claim submitted under it. A remote monitoring contract with a 60-day notice clause, a billing system with the old threshold loaded, or an intake process with no slot for a separate visit all run longer than that. This piece is a calendar and four decisions, not a repeat of the rate maths we covered in the 5 October fee schedule analysis.

The calendar, with the numbers that set it

CMS released the CY 2027 Physician Fee Schedule proposed rule on 14 July 2026 and it appeared in the Federal Register on 16 July (91 FR 43842, per HFMA, July 2026). The 60-day comment period closed on 14 September 2026 and drew 44,287 comments (Medical Economics, September 2026). CMS is expected to publish the final rule "sometime in November 2026," and unless it changes course, most policies take effect on 1 January 2027.

Three facts follow from that. First, the proposal is no longer in flux in the way a draft usually is, because CMS has had the comments for five weeks. Second, final rules often differ from proposals in detail, so a decision that depends on one exact figure should wait for the final text. Third, decisions that depend on contracts, staffing or software cannot wait that long, because they need weeks, not days. The four calls below are sorted by lead time, longest first.

So what for you: put the final rule's publication on your calendar as a trigger, and start the long-lead items now so that the November date confirms a plan rather than starting one.

Call 1: your remote monitoring vendor

This has the longest lead time. As proposed, remote therapeutic monitoring (RTM) would be paid only when clinical staff employed by the billing practitioner or practice furnish it, which would not cover monitoring supplied by a third-party company (MedBridge, 2026). Staff would not need to be on site, and general supervision would still apply. CMS also proposes limiting RTM to established patients and requiring a separately billable face-to-face initiating visit. CMS separately asks whether the six-code RTM family should shrink to two codes, which would end device supply billing (MedBridge, 2026). The 98975, 98977 and 98985 codes are the ones CMS flags as possibly overvalued.

If any part of your RTM service is delivered by an outside company's staff, read your contract this week for three things: the notice period, whether you can pause rather than cancel, and whether the vendor will state in writing how it plans to meet an in-house staffing rule. A vendor whose answer is "we will see what the final rule says" has told you its plan. We could not confirm from the sources available whether a vendor model can be restructured so the monitoring is performed by your own employed staff, so ask the vendor and your billing adviser rather than assume.

Here is the illustrative arithmetic. If RTM brings in $20,000 a year and a third-party vendor does the monitoring, the exposed amount is the full $20,000, not a percentage. Compare that with the $4,200 swing from the conversion factor on a $250,000 Medicare fee schedule book (1.68% of $250,000). Both figures are our own examples, so replace them with yours. The point holds in most clinics: the RTM line is smaller than the whole fee schedule but can lose a larger share of its own value.

So what for you: send the vendor three written questions before the final rule lands, and put the answers beside a dated cost for bringing monitoring in-house.

Call 2: the intake workflow for a separate initiating visit

If the initiating-visit condition is finalized, RTM discussion and patient consent would happen at a separately billable visit by the billing practitioner, in person or by telehealth (MedBridge, 2026). MedBridge notes that CMS has not said whether a therapy evaluation that also completes device setup and education would count. That gap matters, because a clinic that folds setup into the evaluation today may need a second appointment type tomorrow.

Telehealth gives some room here. The Consolidated Appropriations Act, 2026 extended the geographic and originating site telehealth waivers through CY 2027 (Holland & Knight, July 2026), so a short virtual visit is a lawful option for the initiating step for the whole of the year, subject to your payer and state rules. Check the specifics with your Medicare Administrative Contractor.

The design question is small but time-consuming: which appointment type, how long, who books it, and where consent is recorded. If your scheduling or AI front-desk tool books patients into types you configured years ago, adding one needs a test booking, not a meeting.

So what for you: draft the appointment type and consent wording now, mark it "pending final rule," and decide in a single sitting once the rule publishes.

Call 3: the thresholds loaded in your billing system

This is the shortest task and the most likely to be forgotten. The proposed rule moves the KX modifier threshold from $2,480 to $2,540, a rise of $60 or about 2.4%, based on a 2.5% update to the Medicare Economic Index, and keeps the targeted medical review threshold at $3,000 (Holland & Knight, July 2026). The KX threshold applies per patient per calendar year across physical therapy and speech-language pathology combined, so it is the figure that tells your team when to attach the modifier and document medical necessity.

A stale figure is a quiet error. If your practice management system, a claim-scrubbing tool or a spreadsheet still carries $2,480, claims for a patient between the two figures could carry a modifier the system did not expect, or miss one it should. Neither outcome is dramatic, but both create denials and rework that no one budgeted for in January. The same applies to any AI tool that suggests modifiers: ask the supplier when it will load the final figure and whether the update is automatic.

So what for you: write "update KX and TMR thresholds" on the first-week-of-January checklist, with a named owner, and test with one real patient history before the first batch goes out.

Call 4: what to assume about paying for AI

The proposed rule contains no payment for AI tools. CMS instead issued a request for information on ambient documentation tools, clinical decision support, AI-enabled Annual Wellness Visits and technology-assisted primary care, which it says may inform future payment and quality policy (Holland & Knight, July 2026). A request for information is a question, not a coverage decision. We did not confirm a separate response date for those items beyond the main 14 September comment period.

That shapes the 2027 budget. Any AI purchase has to pay for itself through recovered clinician time, fewer denials or faster follow-up, not through a new Medicare code. We have written about the evidence on that, including how documentation tools compare for physio notes. Remember too that vendor accuracy claims are usually the vendor's own research, which is a source conflict you should weigh. If a salesperson tells you Medicare "is moving to reimburse" AI scribing, ask for the Federal Register page.

One sensible test: pick a single workflow, record minutes for 30 days before and after, and multiply by your own revenue per visit. If a tool handles patient data, confirm a HIPAA business associate agreement is in place before the trial begins.

So what for you: budget AI on time recovered and measured in your own clinic, and treat any payment promise as unverified until it appears in a final rule.

What the evidence points toward

Frankly, the order of work is the reverse of the order of headlines. The conversion factor, at $32.8409 for practices outside an advanced alternative payment model (Holland & Knight, July 2026), gets the attention and is the item you control least. The RTM contract has the longest lead time and the sharpest edge, the threshold update is cheap and easy to miss, and the intake workflow sits between them. Start with the vendor letter this week, draft the appointment type next week, and keep the final rule date free for decisions rather than discovery.

None of this is billing, legal or financial advice, and the rule is still a proposal. If you want a ranked list of which workflows in your clinic deserve automation before you commit a 2027 budget, an AI Opportunity and Growth Assessment builds that list from your own numbers, or you can book a free 20-minute call.

Related: Medicare PT rate -1.68%, but RVUs rise 1-3%  ·  What prior authorization costs a physio practice  ·  The accuracy-testing gap in AI scribes

Figures are from the CY 2027 Medicare Physician Fee Schedule proposed rule (released July 14, 2026; Federal Register July 16, 2026) as summarized by Holland & Knight (July 2026), HFMA (July 2026), MedBridge (2026) and Medical Economics (September 2026). The $4,200 and $20,000 examples are our own illustrative arithmetic, not CMS figures. The 13-day and 74-day counts run from 19 October 2026. The final rule date is an expectation, not a CMS commitment. The rule is proposed, not final. This article is for informational purposes only and does not constitute clinical, legal, billing or financial advice.