CMS-1850-P: Role-Based Impact Brief — Software as a Medical Service (SaMS)
CMS proposes to create the first Medicare payment category dedicated to Software as a Medical Service (SaMS). A new status indicator O1 would flag 46 HCPCS codes as SaMS, effective January 1, 2027 if finalized as proposed.
The rule
For most hospitals the direct APC-payment delta is modest at code level. The bigger effects are structural: patient liability shifts for the 10 CLFS-to-OPPS lab codes, vendor contract exposure as algorithm licenses become the marginal cost, revenue-cycle rework as status indicators and APC assignments change simultaneously, and a new SaMS-specific status indicator your CDM, coding, and denial-management logic have never seen before.
What's inside
- Full 46-code crosswalk: current versus proposed APC, SI, and payment
- Department impact map: Cardiology, Radiology, Pathology, Ophthalmology, Urology
- Patient-liability shifts and denial-risk exposure for the CLFS-to-OPPS move
- Vendor-contract audit checklist and Q3-2026 action plan
- Public comment guidance and source citations from CMS-1850-P and CY2027 Addendum B
Every APC, SI, and payment figure was pulled directly from the CMS-1850-P NPRM PDF and cross-referenced against the CY2027 Addendum B. No secondary-source counts were relied on.
Who this is for
CFOs, Revenue Cycle, HIM/Coding, Compliance, Digital Health, and Payer Underwriters preparing for the January 2027 go-live.
What you get
You receive the full role-based impact brief as a PDF, delivered by email immediately after purchase. This does not include access to PAULA's live platform or ongoing updates.
No email list. No upsell funnel. You get the PDF.