Navigating the CY2027 Proposed Changes: How StrataPT Protects Your Revenue & Supports Your Practice

Oct 22, 2026 · Mariah Tichacek, Senior RCM Operations Manager

As CMS works toward finalizing the 2027 Medicare Physician Fee Schedule (CMS-1848-P), therapy practices face a  shift in both policy and coding. StrataPT actively tracks every detail so nothing gets lost and your revenue stays on track.

Beyond processing claims, our team navigates regulatory shifts alongside the practices we serve, absorbs the administrative burden, and safeguards cash flow so owners and clinicians can stay focused on patients.

A Quick Look at What’s Pending vs. Final

CMS published the CY2027 Proposed Rule in July 2026, with public comments closing in September 2026. These payment policies and regulations remain proposed until CMS releases the CY2027 Final Rule, expected in early November.

While the industry waits for official confirmation on final rates and policy decisions, our engineering and RCM teams are  laying the groundwork for our practices so they don’t miss a beat come January 1.

Key Regulatory Highlights Across Specialties

• Speech-Language Pathology (SLP): CPT 92507 (untimed individual therapy) is set to be retired on December 31, 2026. It will be replaced by 10 new timed codes (5 initial 30-minute base codes and 5 15-minute add-on codes) categorized by disorder focus, alongside a proposed untimed pediatric G-code (GSLPP).
• Remote Therapeutic Monitoring (RTM): CMS proposes requiring established-patient status, an initial reportable visit, and W-2 practice employment for monitoring staff, along with revised device valuations.
• Physical & Occupational Therapy: Core treatment families remain stable. The baseline Medicare conversion factor proposes a -1.68% reduction, but proposed practice-expense (PE) methodology changes may offset cuts for several high-volume PT and OT codes. AOTA projects a ~3% overall RVU increase for OT.
• Biofeedback (90901): Code 90901 shifts to an initial 15-minute code, supported by a new 15-minute add-on code.
• Annual Thresholds: The proposed CY2027 Therapy Threshold (KX modifier) is set at $2,540 (PT + SLP combined; OT separate).

How StrataPT Tackles Regulatory Changes 

Regulatory change shouldn’t mean more work for your clinicians or operations staff. Here’s how StrataPT absorbs it so the transition creates zero friction:

1. Eliminating manual calculations for SLPs. We’re building native timed-code logic directly into daily note documentation. The system enforces midpoint timing rules and base/add-on dependencies automatically, preventing manual math errors and freeing clinicians to focus entirely on patient care.
2. Payer adoption matrixing. Medicare adoption of new rules is automatic, but Medicaid and commercial insurers update on their own schedules. We actively track payer-by-payer adoption across all active regions to verify which payers are adopting new codes versus requiring legacy billing crosswalks.
3. Automated fee schedule updates. Once CMS posts final rates, our team updates fee schedules across the platform and models code-level revenue impact. Practices get full visibility into 2027 reimbursement trends through our Medicare Fee Calculator.
4. Enhanced post-go-live monitoring. We don’t just hit “go” and walk away.. Our team monitors claim processing far more closely than standard protocol, tracking clean claim rates, first-week rejections, and clearinghouse edits to resolve payer adjudication hiccups in real time.

What to Expect Next

As soon as CMS releases the Final Rule in November, we’ll deliver updates to our customers, code-level payment analysis, and clinical documentation guidance to every practice. 

We’re proud to be a trusted advisor and partner to therapy practices through this transition. If you’re curious how these proposed changes could affect your practice, reach out to our team and we’ll walk you through step by step.