Prepared for Alaska Heart & Vascular Institute · Remote Care Deployment & Value Model · Confidential — not for distribution
Heart Failure · Hypertension · Envoy Integrated Health ACO · Anchorage, Alaska

A Scalable, Profitable Remote Care Service Line for Alaska Heart & Vascular Institute, Built Around Envoy.

Three patient lanes, sorted by who bears the economics. Broad enrollment where AHVI keeps the margin and no ACO benchmark is touched. Selective post-discharge enrollment where care-management spend enters Envoy's benchmark and has to earn its place. One infrastructure that serves fee-for-service today, Envoy's total cost of care now, and the Ambulatory Specialty Model from 2027.

$0
36-Month Net to Practice (After Fees)
0%
Practice Margin on Net Reimbursement
$0
Net to Practice in Month One · $0 Upfront
0
Patients in Active Remote Care (Month 36)
Enterprise value, kept separate$834K36-month net total-cost-of-care benefit to Envoy Integrated Health ACO. Value to Envoy, not AHVI practice revenue, and excluded from every figure above.
Deployment Strategy

Who Bears the Economics Decides the Enrollment Strategy

AHVI founded Envoy Integrated Health ACO. That changes the arithmetic of a remote care program. For a patient outside any ACO benchmark, every dollar of RPM and PCM is practice margin. For a patient Envoy is accountable for, the same dollar also raises Envoy's benchmark, and the program has to avoid enough admissions to pay that back. The deployment below sorts every Medicare heart failure and hypertension patient on that one question first, and the clinical context second.

The question

Is the patient Envoy-attributed?

Retrospective assignment means the operational filter is the referring primary care physician: the six Envoy primary care TINs. Roughly a third of AHVI's heart failure panel sits inside the benchmark; two thirds sits outside it.

Outside the benchmark

Enroll broadly. The margin is AHVI's.

Non-attributed heart failure and hypertension patients bill RPM and PCM with no ACO exposure at all. Breadth is free, so these two lanes are staffed to run at full enrollment-specialist capacity from month one.

Inside the benchmark

Enroll selectively. The lane has to clear a test.

Only a post-discharge heart failure cohort avoids enough admissions to outrun the care-management spend it adds to Envoy's benchmark. So attributed patients enter through a qualifying discharge, not a panel sweep.

Lane A · Non-attributed heart failureLane B · Envoy-attributed heart failureLane C · Non-attributed hypertension
PopulationNon-attributed HFEnvoy-attributed HFNon-attributed HTN without HF
Primary programRPM + PCMTCM + RPM + PCMRPM + selective PCM
Enrollment triggerEligible HF patientQualifying acute dischargeActive HTN management need
Deployment postureBroadSelectiveBroad
Primary beneficiaryAHVIAHVI + EnvoyAHVI
Clinical objectiveLongitudinal HF managementFewer readmissions and ED visitsBlood-pressure control and longitudinal management
Key economic riskEnrollment throughput and operating capacityCare-management spend enters the ACO benchmarkEnrollment capacity, PCM eligibility and documentation

Broad enrollment makes sense where AHVI captures the economics directly. Attributed beneficiaries require a higher clinical-value threshold, and the model holds Lane B to it.

Population Segmentation

17,049 Medicare Patients. Two Cohorts. Three Lanes.

AHVI's own census: 5,038 Medicare patients with heart failure and 12,011 with hypertension and no heart failure. The two cohorts are mutually exclusive, so nothing here is counted twice. The Envoy split is applied to both.

5,038Heart failure

Medicare heart failure patients, the cohort the Ambulatory Specialty Model will measure AHVI on from January 2027.

35%65%
~1,763 Envoy-attributed, inside the benchmark~3,275 non-attributed, outside any ACO benchmark
Lane B · attributed
~308
steady-state census, fed by qualifying post-discharge flow rather than panel penetration
Lane A · non-attributed
~1,146
census ceiling at 35% penetration of the non-attributed pool
12,011Hypertension without HF

Medicare hypertension patients. Heart failure patients are already excluded from this count, so Lane C cannot overlap Lanes A or B.

35%65%
~4,204 Envoy-attributed, not enrolled~7,807 non-attributed, the Lane C pool
Lane C · 30% enrollment
~2,342
census ceiling, the largest single pool in the deployment
PCM attach
70%
applied only to the documented uncontrolled-hypertension slice, never the whole enrolled cohort
AHVI has more addressable demand than the initial operating model can enroll in 36 months. Lane C in particular ends the horizon still climbing, at roughly 2,238 of a 2,342 ceiling. The constraint on this deployment is enrollment throughput, not patients.
Deployment Architecture

Three Patient Lanes, Three Value Engines

Each lane connects a population to a program, a posture, and the engine it feeds. The same enrollment specialists, devices, monitoring, and athenaOne integration run all three.

Lane A
Non-attributed Heart Failure
Who
Heart failure patients whose primary care physician is not in an Envoy TIN
Program
RPM + PCM for every enrolled patient
Deployment
Broad enrollment · ~3,275 available · ~1,146 modeled census ceiling
Objective
Maximize direct AHVI practice economics with longitudinal heart failure management
$2.99M
36-month net to practice
Lane B
Envoy-attributed Heart Failure
Who
Attributed heart failure patients after a qualifying acute discharge
Program
TCM + 12 months of RPM + PCM at a 70% attach
Deployment
Selective post-discharge · flow-based, not panel-based · ~308 steady-state census
Objective
Reduce avoidable acute utilization at positive practice economics, and clear Envoy's break-even
$1.04M
36-month net to practice · plus $834K net TCoC benefit to Envoy
Lane C
Non-attributed Hypertension
Who
Hypertension patients without heart failure, outside the Envoy benchmark, with an active management need
Program
RPM across the census + PCM on the documented uncontrolled slice
Deployment
Broad enrollment · ~7,807 pool · ~2,342 ceiling · 70% PCM attach
Objective
Scale the largest direct practice-margin opportunity in the deployment
$4.03M
36-month net to practice
Engine 1 · AHVI practice economics
$8.07M
36-month practice net at a 46.9% margin: direct reimbursement less program operating cost.
Primary business case
Engine 2 · Envoy ACO economics
$834K
36-month modeled net total-cost-of-care benefit from Lane B. Value to Envoy, kept out of the AHVI figures.
Enterprise value
Engine 3 · ASM strategic upside
15 clinicians
On the preliminary CY2027 participant list, with a $5.91M historical Part B base under a two-sided adjustment from 2029.
Secondary · scenario-based
Scale aggressively where AHVI captures the economics directly; deploy selectively where program spend enters the ACO benchmark. Roughly 87% of modeled practice net comes from the two non-attributed lanes. The same infrastructure then carries strategic value as specialty reimbursement shifts toward ASM.
Operating Model

Two Enrollment Engines, About 160 New Patients a Month

Two dedicated, CoachCare-funded enrollment specialists, each with roughly 80 enrollments a month of capacity. One runs heart failure and staffs the post-discharge window first. The other runs hypertension and nothing else.

Enrollment specialist 1 · Heart failure

~80 enrollments a month, Lane B first

Lane B, ~29 a month. Qualifying post-discharge heart failure patients are staffed first. The post-discharge window is perishable, and Lane B is the only lane whose enrollment has to clear an avoided-utilization test, so it gets capacity before anyone else.

Lane A, ~51 a month. Non-attributed heart failure absorbs whatever capacity Lane B leaves, until Lane A reaches its 1,146 ceiling in month 27 and drops to replacement enrollment.

Enrollment specialist 2 · Hypertension

~80 enrollments a month, all of it Lane C

The full specialist runs one lane. Against a 7,807-patient pool and a 2,342 ceiling, 80 a month less attrition reaches about 2,238 active patients by month 36. Lane C becomes capacity-constrained before it becomes population-constrained.

Additional enrollment capacity is a future scale lever, once the economics and clinical performance validate. The population is not the binding constraint.

What AHVI Pays
Implementation and athenahealth integration setup are waived. The only recurring platform charge outside the per-patient program fees is the $150 a month athenahealth EHR line, carried as operating expense. Every other cost is variable and scales with the census it serves: platform, devices, monitoring, care-management time, and the TCM episode fee on Lane B.
What AHVI Staffs
Enrollment outreach, the two enrollment specialists, device logistics, bush shipping, and consent are delivered at CoachCare's expense and never subtracted from practice margin. AHVI's clinical team keeps the escalation decisions and the PCM care plans. Native athenaOne integration puts readings, care-plan time, and billing in the chart AHVI already uses.
What Runs the Ramp
A flat 160 new enrollments a month across the three lanes for the first two years, tapering as Lane A fills. Active census reaches 1,755 patients at month 12, 2,978 at month 24, and 3,692 at month 36, net of attrition.
The Value Model · AHVI practice ledger

The Value Analysis

A 36-month forecast of the three lanes on AHVI's own census, at Anchorage Medicare rates, net of denials and coinsurance bad debt, after every CoachCare fee. Launch is modeled at January 2027, alongside the first ASM performance year.

Active Census by Lane

Patients in active remote care at month end. Lane A climbs to its 1,146 ceiling by month 27; Lane B steadies near 308; Lane C is still climbing at month 36, at 2,238 of a 2,342 ceiling.

Monthly Economics — Net Reimbursement, Fees, Net to Practice

Net reimbursement after denials and bad debt against total CoachCare fees. Net to the practice is positive in month one (+$19,139) and every month after, reaching about $356K a month by month 36.

36-Month Practice Net by Lane

$8.07M in total. The two non-attributed lanes carry about 87% of it.

The Financial Summary

Line20272028202936-Month
Net reimbursement, all lanes$2,538,038$6,151,735$8,508,737$17,198,510
CoachCare fees, all lanes$1,332,888$3,266,969$4,531,505$9,131,362
Net to practice (after fees)$1,205,150$2,884,766$3,977,233$8,067,148
Lane A · non-attributed HF$440,079$1,088,621$1,466,104$2,994,803
Lane B · attributed HF$229,209$403,914$404,573$1,037,695
Lane C · non-attributed HTN$535,862$1,392,231$2,106,556$4,034,650
Practice margin47.5%46.9%46.7%46.9%

Full model available as a companion Deployment Value Model workbook.

The Investment Case

Self-Funding From Month One, With No Upfront Capital

With implementation and integration waived, the deployment is purely variable-cost. Expense scales alongside reimbursable events, so there is no payback period to finance and no modeled month in which cumulative cash is negative. The decision is less about financing a long payback than about validating enrollment throughput, clinical eligibility, reimbursement realization, and operational execution.

Upfront setup
$0
Implementation and athenahealth integration setup waived
Month 1
+$19K
$39K net reimbursement less $20K program cost
Month 12 · cumulative
$1.21M
~$174K a month by then
Month 36 · cumulative
$8.07M
~$356K a month by then

Cumulative Net to Practice

Break-even is month one. Milestones at months 12, 24, and 36.
Net reimbursement, 36 months$17.20M
less modeled remote care program expense−$9.13M
Direct practice net$8.07M
plus ASM cash received in the 36-month window (2029 payment)$240K
plus Envoy participant distributions to AHVI$9K
Total modeled AHVI value, 36 months$8.32M
Kept separate: $834K of modeled Envoy net total-cost-of-care benefit. It is relevant to the enterprise relationship and is not treated as AHVI practice revenue anywhere on this page.

Scenario Explorer — Build Your Own Forecast

The practice ledger, recomputed live with the same lane mechanics as the model: attribution splits the pools, each enrollment specialist supplies 80 a month, Lane B staffs the post-discharge flow first, and every lane stops at its ceiling or its pool. Envoy and ASM figures stay on their own sections.
36-mo net reimbursement
$17,198,510
36-mo net to practice
$8,067,148
Practice margin
46.9%
Active patients · M36
3,692
Month-1 net to practice
+$19,139
Avoided HF admissions · 36 mo
~524

Attribution moves both pools at once: a higher Envoy share shrinks Lanes A and C and enlarges the discharge flow feeding Lane B. Penetration and enrollment rate set each lane's ceiling; the specialists set how fast the lane climbs toward it. Once a lane stops reaching its ceiling inside 36 months, a higher ceiling buys runway past month 36 rather than a larger 36-month total.

~524

HF Admissions Avoided

Across the two heart failure lanes over 36 months, at a 40% reduction on a 40% annual admission rate. Lane C claims revenue only.

~153

Lane B Admissions Avoided

The attributed post-discharge cohort alone, with about 92 emergency department visits avoided beside them.

Lane A Patients Enrolled

Cumulative over 36 months, against 1,029 post-discharge enrollments in Lane B and 2,880 in Lane C.

Modeled Scale Horizon

Monthly for all three lanes, with ASM shown by payment year and Envoy by performance year.

Envoy ACO Economics

Lane B Pays Its Way Inside Envoy's Benchmark

Every Lane B care-management dollar raises Envoy's benchmark. Selective post-discharge enrollment lets the avoided admissions and emergency visits outweigh that spend, so the lane improves Envoy's total cost of care while AHVI still earns positive practice economics on it.

Incremental ACO expenditure
~$687K

a year at steady state

Care-management spend that lands inside the Envoy benchmark: 0.95 points of it, against a 1.5-point budget.

Avoided utilization
~$1.04M

a year at steady state

Gross utilization savings from roughly 62 admissions and 37 emergency department visits avoided each year on a ~308-patient census.

Net total-cost-of-care benefit
+$351K

a year · 0.49 points of benchmark

$834K over 36 months. About 153 admissions and 92 ED visits avoided across the horizon.

Principal care management attach on Lane B0%25%50%70% · modeled100%
Benchmark drag0.61 pts0.73 pts0.86 pts0.95 pts1.10 pts
Net TCoC benefit to Envoy+$599K/yr+$511K/yr+$422K/yr+$351K/yr+$244K/yr
Avoided admissions needed per 100 to break even8.9 of 2010.7 of 2012.5 of 2013.9 of 2016.1 of 20
AHVI Lane B net$246K/yr$303K/yr$359K/yr$405K/yr$472K/yr

Every point of attach moves both directions at once: it raises what Envoy absorbs and raises the avoided admissions the lane must deliver to pay for itself. The modeled cohort delivers 20 avoided admissions per 100 enrollee-years, so the lane clears at every attach shown, with 1.44× cushion at the modeled 70%.

Minimum savings rate
3.53%

~7.54 points of modeled year-three cushion

Total ACO savings must clear the MSR before any savings are shared. Below it, distributable shared savings fall to zero regardless of how well Lane B performs. The cushion is the number to watch.

Quality-adjusted sharing rate
39.2%

at or above the 73.85 quality threshold

About 27.8% at Envoy's 71.03 reference score. The same avoided utilization is worth roughly a third less below the threshold, which yields ~$138K of incremental earned savings at the year-three run rate.

AHVI participant distribution
~$4K

a year, deliberately drawn small

After the infrastructure, care-redesign, and participant allocations, AHVI's share of the distribution is minor. The enterprise value sits in total cost of care, not in the distribution check. AHVI gets rich on practice margin.

ACO economics strengthen the enterprise case for Lane B, but remain secondary to AHVI's direct fee-for-service investment case.

Ambulatory Specialty Model

ASM Raises the Value of Building Heart Failure Infrastructure Now

Fifteen AHVI clinicians appear on CMS's preliminary CY2027 participant list for the heart failure cohort, on a historical Part B base of about $5.91M. From the 2027 performance year, paid in 2029, that base carries a two-sided adjustment that widens every year. The remote monitoring, post-discharge intervention, and longitudinal management the three lanes deliver are the same work ASM measures.

Performance 2027
paid in 2029
±9%
selected scenario +$240K
Performance 2028
paid in 2030
±9%
selected scenario +$245K
Performance 2029
paid in 2031
±10%
selected scenario +$277K
Performance 2030
paid in 2032
±11%
selected scenario +$311K
Performance 2031
paid in 2033
±12%
selected scenario +$346K
Exposure base

Preliminary AHVI clinicians

ASM adjustments apply to covered professional Part B reimbursement broadly, not only to remote care claims. That is what makes the exposure base $5.91M rather than the program's own billing.

Clinical-economic bridge
1.034 → 0.980

Directional modeled observed-to-expected cost

Fewer inpatient and emergency events, plus better expected-cost capture, from the two heart failure lanes at a 60% ASM-managed share of the census. A direction, not a predicted CMS score.

Selected scenario
~$1.42M

Five-year selected scenario, 2029 to 2033

Only the 2029 payment (~$240K) falls inside the 36-month window, and it is the one ASM figure carried into the total AHVI value above. The maximum downside at a zero score runs $564K in the first payment year.

The direct fee-for-service business case stands on its own. ASM is secondary and scenario-based; it raises the strategic value of the same clinical infrastructure rather than justifying it.
Executive Recommendation

Launch at Controlled Scale. Validate. Then Expand the Highest-Return Lanes.

Proceed with a three-lane deployment: maximize direct practice economics in the non-attributed populations, selectively manage attributed heart failure patients where acute-utilization savings justify the ACO spend, and use the resulting infrastructure to strengthen AHVI's position as specialty reimbursement moves further toward value.

Population

Validate the actual Envoy attribution overlap.

Operations

Validate real enrollment conversion and staffing capacity.

Clinical

Validate utilization and hypertension management outcomes.

Value-based care

Confirm ASM participation; monitor Envoy's MSR and quality.

Phase 1 · Launch · 2026

Stand up the infrastructure

Implement remote care infrastructure, activate the two enrollment specialists, launch all three patient lanes, establish the financial and clinical baselines, and operationalize the athenaOne integration.

Phase 2 · Validate · months 1 to 12

Measure what the model assumed

Enrollment conversion and throughput. Net reimbursement and practice margin. Heart failure admissions, ED utilization, and blood-pressure control. PCM eligibility and documentation. ACO economics and ASM-related heart failure performance.

Phase 3 · Scale · month 12 onward

Add capacity where it earns its place

Add enrollment capacity where realized contribution margin stays attractive, retention validates the assumptions, clinical outcomes support deployment, Lane C demand still exceeds throughput, and AHVI operating capacity supports expansion.

What We Need From You

Every Figure Rests on an Input. Nine of Them Are Yours to Replace.

Where AHVI's data was unavailable we used a documented placeholder rather than a guess, and tiered each one by how far it moves the forecast. Replacing an assumption is one cell, not a rebuilt analysis.

InputModeledWhere the real value comes from
Tier one · moves the forecast most
Share of HF patients attributed to Envoy35%Envoy's attribution feed, or a query of your HF patients against the six Envoy primary care TINs by referring physician.
Annual hospitalization rate, HF cohort40%athenaOne joined to hospital discharge records; Envoy's claims feed for the attributed share.
Share of discharges the program captures50%Your HF clinic's current 7-to-14-day post-discharge follow-up rate. Clinical director and APP leadership.
Tier two · shifts the ACO and ASM layers
Medicare cost per acute admission, Alaska$16KEnvoy's claims data: actual Medicare paid amounts on HF admissions for attributed patients.
12-month readmission rate, post-discharge50%Hospital readmission reporting or your own follow-up data. The break-even test is most sensitive to this.
HF episode cost, observed and expected$30K / $29KYour CMS episode-based cost measure feedback report, via the QPP portal.
Share of census managed by ASM clinicians60%The same CMS feedback report, or your own general-versus-procedural clinician split.
Tier three · fine-tunes the revenue model
Denial rate and coinsurance collection2.5% / 75%Revenue cycle reporting. Sets the 92.6% gross-to-collected conversion, which moves every figure proportionally.
Envoy savings rate and distribution terms10.58%Envoy directly: its 2025 performance results and the participation agreement's terms across 14 practices.
The single most useful document

The CMS episode-based cost measure feedback report

Available through the QPP portal. It replaces four separate placeholders in the Ambulatory Specialty Model layer at once, and it is the highest-value single document for that half of the analysis.

Two figures we defend, not you

The 40% admission reduction and the 70% PCM attach

One admission-reduction lever drives Lane A's clinical impact, Lane B's avoided admissions, and the ASM inpatient bucket, so the model cannot claim different effect sizes in different rooms. The PCM attach on Lane C is a modeling estimate of the documented uncontrolled share, and a chart review is what confirms it.

About CoachCare

The Experience to Get It Right

The deployment described on this page runs on infrastructure already proven at national scale.

500,000+

Patients Managed

Over 400 managed conditions for 500,000+ patients.

10,000+

Clinicians on the Platform

Providers running remote care programs day to day.

1,000+

Implementations

Programs stood up and running in market.

5M+

Claims Generated

Care-plan coding and billing behind more than 5 million claims.

100M+

Vitals Recorded

Over 100 million vitals recorded; 4 million+ care actions enabled.

Policy Watch · CMS-1848-P

2027 Proposed Rule Insights

CMS's CY2027 Physician Fee Schedule proposed rule, published July 16, 2026, proposes to reprice remote physiologic monitoring. Here is what it reaches, what it leaves alone, and how the deployment on this page absorbs it.

1
Scope

The Proposal Is Confined to RPM

CMS's remote-monitoring proposals sit in one code family: RPM. CCM, PCM, and TCM are not part of them. That lands directly on this forecast: PCM carries $7.50M of the modeled $17.20M in 36-month net reimbursement, and the TCM episode that opens every Lane B enrollment adds $272K more. Neither is in scope.

2
Operating Model

CoachCare Is Building the Contingencies Now

The delivery model has more than one shape, and CoachCare is preparing each so the deployment's economics hold wherever the rule settles. One unbundles the program into its parts, SaaS platform, device logistics, and program enablement, priced as components. Another engages CoachCare to run the staffing itself, an MSO-style arrangement in which AHVI owns the clinical program and the billing while CoachCare carries the labor model. Neither requires re-architecting the three lanes.

3
What Comes Next

ACCESS Moves Remote Care to Risk-Based PMPM

Alongside the fee schedule, CMS's ACCESS Model pays remote care as a risk-based per-member-per-month arrangement rather than per code: recurring per-beneficiary payments, half of each one withheld and reconciled against outcome attainment. Cardiometabolic care is among its four clinical tracks. What earns under that structure, controlled pressures, titrated GDMT, decompensations caught early, is what this deployment is built to produce.

What the Proposal Actually Takes Off This Forecast

AHVI's own 36-month forecast repriced code by code at CMS's CY2027 proposed values, at AHVI's Alaska MAC locality (Noridian 02102-01) rather than national averages. Same enrollment, same three lanes, same fees. Only the rates move.
−20.6%
The headline per-code cut: device supply (99454 / 99445), the code the proposal reprices hardest.
−9.1%
The RPM patient-month in this model, because device supply is only 29% of it. The management codes barely move.
−5.2%
The whole deployment, because PCM and TCM carry 45% of the forecast and are untouched.
RPM alone — the only code family in scope$9,421,627 over 36 months
−$852,852
−9.1% of RPM
The whole deployment — RPM + PCM + TCM$17,198,510 over 36 months
−$890,647
−5.2% of the whole

Both bars run on the same dollar scale, so the red slice is nearly the same width in each: the same dollars, measured against a larger base. The empty track on the top bar is the PCM and TCM revenue RPM alone does not include.

RPM, retained at CY2027 proposed rates The proposed reduction PCM — not in scope TCM — not in scope

Repriced at Alaska's own geographic adjusters, which cushion the reduction: the RPM cuts fall almost entirely on practice expense, and Alaska carries a statutory 1.5 work GPCI, the highest in the country, so the untouched work component is weighted more heavily here than anywhere else. Of the $890,647, RPM accounts for $852,852 and PCM for $37,795; TCM does not move.

Where the Proposal Lands, Code Family by Code Family

CY2026 versus CMS's published CY2027 proposed values, shown at national non-facility amounts so they can be read against CMS's own tables. AHVI's locality-adjusted amounts run above these; the forecast repricing above uses the Alaska figures. The programs in this forecast are RPM, PCM, and TCM.

Code familyWhat CMS proposedCY2026CY2027 proposedChange
In scope — remote physiologic monitoring
99454 / 99445 · device supplyPractice expense recrosswalked$52.11$41.38−21%
99470 · management, 10 minPractice expense recrosswalked$26.05$20.69−21%
99457 · management, first 20 minDirect practice expense removed$51.77$49.59−4%
99458 · management, each addl 20 minDirect practice expense removed$41.42$40.39−2%
99453 · setup and patient educationCrosswalked; one-time per patient$21.71$20.03−8%
Not in scope — the codes the proposal does not reach
99426 / 99427 · PCMNo structural change proposed$67.80$67.00−1%
99490 / 99439 / 99491 · CCMNo structural change proposed$66.13$64.04−3%
99495 / 99496 · TCMNot addressed by the proposalOutside the remote-monitoring provisions entirely

National non-facility amounts; CY2027 values are CMS's own published proposals in Addendum B of CMS-1848-P. PCM and CCM rows show the lead code in each family; every code in both families moves within a few percent in either direction, which is ordinary annual movement rather than a repricing. The RPM reductions are also phased: section 1848(c)(7) of the Act caps any one code's total-RVU reduction at 19% in a single year, and CMS publishes the affected codes, so CY2027 is a single-digit year for a typical program and the remainder arrives no earlier than CY2028.

None of this is final. CMS-1848-P is a proposed rule. The comment period closes September 14, 2026, the final rule is expected in early November, and it takes effect January 1, 2027. CoachCare is leading the advocacy: filing comments, putting the device cost and pricing evidence in front of CMS that the rule itself states the agency does not have, and helping practices file their own. AHVI gets the final rates, and the model rerun against them, the week they publish.