---

type: claim
domain: health
description: "CMS adding category I CPT codes for AI-assisted diagnosis (diabetic retinopathy, coronary plaque) and testing category III codes for AI ECG, echocardiograms, and ultrasound — creating the first formal reimbursement pathway for clinical AI"
confidence: likely
source: "Bessemer Venture Partners, State of Health AI 2026 (bvp.com/atlas/state-of-health-ai-2026)"
created: 2026-03-07
supports:
  - "consumer willingness to pay out of pocket for AI enhanced care is outpacing reimbursement creating a cash pay adoption pathway that bypasses traditional payer gatekeeping"
reweave_edges:
  - "consumer willingness to pay out of pocket for AI enhanced care is outpacing reimbursement creating a cash pay adoption pathway that bypasses traditional payer gatekeeping|supports|2026-03-28"
---

# CMS is creating AI-specific reimbursement codes which will formalize a two-speed adoption system where proven AI applications get payment parity while experimental ones remain in cash-pay limbo

CMS is building the reimbursement infrastructure for clinical AI through a graduated code system. Category I (permanent) CPT codes now exist for AI-assisted diabetic retinopathy autonomous screening, with coronary plaque assessment AI added in 2026. Multiple category III (temporary/experimental) codes are under testing for AI-augmented ECG interpretation, echocardiogram analysis, and breast/thyroid ultrasound.

This creates a formal two-speed adoption system:

**Speed 1: Reimbursed AI (CMS-paced).** Applications that earn category I codes get payment parity with traditional clinical procedures. This unlocks provider adoption at scale because the economic model works within existing revenue cycles. Diabetic retinopathy screening was first because it has the cleanest evidence base — FDA-cleared autonomous AI (IDx-DR/LumineticsCore) with randomized trial data showing non-inferiority to ophthalmologists.

**Speed 2: Cash-pay AI (consumer-paced).** Applications without reimbursement codes depend on consumer willingness to pay or provider willingness to absorb cost. RadNet's AI mammography ($40 consumer co-pay, 36% uptake) and Function Health ($499/year direct-to-consumer) demonstrate this pathway works but creates access inequality.

The two-speed system has a structural feedback loop. Category III codes generate real-world evidence data on AI performance, outcomes, and cost-effectiveness. This evidence supports the transition to category I codes. But the 3-5 year timeline from category III testing to category I permanence means the reimbursement system inherently lags clinical capability by half a decade.

Since [[healthcare AI regulation needs blank-sheet redesign because the FDA drug-and-device model built for static products cannot govern continuously learning software]], the CPT code system faces a similar structural problem: codes are static descriptions of procedures, but AI capabilities evolve continuously. A coronary plaque assessment AI in 2026 will be materially different from the same product in 2028, yet the reimbursement code remains fixed.

The investment implication: companies positioned at the category I boundary — where evidence is sufficient for permanent reimbursement — capture disproportionate value. The transition from category III to category I is the healthcare AI equivalent of the regulatory moat. Since [[value-based care transitions stall at the payment boundary because 60 percent of payments touch value metrics but only 14 percent bear full risk]], AI reimbursement codes could accelerate VBC transition by making AI-assisted prevention and chronic disease management economically viable within fee-for-service billing.

---

### Additional Evidence (extend)
*Source: [[2025-12-05-fda-tempo-pilot-cms-access-digital-health-ckm]] | Added: 2026-03-31*

TEMPO + CMS ACCESS model formalizes a two-speed system at an earlier stage: pre-clearance devices get Medicare reimbursement through ACCESS while collecting evidence, versus cleared devices with standard coverage. This creates a research-to-reimbursement pathway that didn't exist before January 2026, but scale is limited to ~10 manufacturers per clinical area.

### Additional Evidence (extend)
*Source: [[2026-04-01-fda-tempo-cms-access-selection-pending-july-performance-period]] | Added: 2026-04-01*

TEMPO + ACCESS coordination demonstrates the two-speed system in practice: Medicare beneficiaries (65+) gain access to FDA-approved digital health devices through TEMPO while Medicaid populations face coverage contraction. The ACCESS model's July 1, 2026 performance period start creates a defined timeline for when Medicare digital health infrastructure becomes operational, while no equivalent pathway exists for Medicaid populations.



Relevant Notes:
- [[healthcare AI regulation needs blank-sheet redesign because the FDA drug-and-device model built for static products cannot govern continuously learning software]] — the static-code problem applies to CMS as well as FDA
- [[value-based care transitions stall at the payment boundary because 60 percent of payments touch value metrics but only 14 percent bear full risk]] — AI codes could bridge the payment gap
- [[AI diagnostic triage achieves 97 percent sensitivity across 14 conditions making AI-first screening viable for all imaging and pathology]] — the clinical capability awaiting reimbursement infrastructure
- [[the healthcare attractor state is a prevention-first system where aligned payment continuous monitoring and AI-augmented care delivery create a flywheel that profits from health rather than sickness]] — reimbursement codes are a prerequisite for the attractor state within fee-for-service

Topics:
- [[_map]]
