2026 is expected to be a year of change for coding for AI and software-based health care services. The standard code set for reporting services on outpatient claims is the Current Procedural Terminology (CPT®)[1] which is maintained by the American Medical Association (AMA). To date, AI and other software-based services that have a distinct beginning, middle, and end have been able to apply for and receive traditional Category I and Category III CPT codes. This has facilitated reimbursement by Medicare and led to the success of many of the first AI and software-based services used in clinical practice today.

In 2025, a CPT workgroup, the Digital Medicine Coding Committee (DMCC), began efforts to change "Appendix S: Taxonomy for AI Medical Services and Procedures." This taxonomy describes distinct categories of AI and software-based services (e.g., those that are assistive, augmentative, and autonomous). DMCC also proposed the creation of a new coding framework specifically for AI-based services, called the "Clinically Meaningful Algorithmic Analysis" (CMAA). With respect to Appendix S, the CPT Editorial Panel will formally consider changes at the May 2026 CPT Editorial Panel Meeting. If adopted, these changes could signal a substantial shift in the CPT code application and evaluation process for AI and software-based services.

Perhaps the bigger impact though would come from a new CMAA code set for AI medical services and procedures. Creation of a new code set outside of the traditional CPT coding structure would present many challenges and opportunities for developers of these technologies. Much like the early creation of Category III CPT codes and Proprietary Laboratory Analysis (PLA) codes, there is significant risk of initial non-coverage and non-payment for services described by a new code set. Although Category III CPT codes now have broader acceptance amongst payors, they were initially broadly rejected as experimental, and it took many years of advocacy by stakeholders to change this perception of services described by Category III CPT codes. There is a risk that the same non-coverage and non-payment trajectory could apply to a new code set for AI and software-based services. On the other hand, it is laudable that DMCC is considering how to create codes more quickly for AI and software-based services and improve patient access. This certainly could be helpful for commercialization, provided the doors for coverage and payment are not foreclosed.

Companies with technologies seeking codes now, and those with technologies in the pipeline, should be aware of these potential coding changes, as they could change the reimbursement strategy for these technologies in the short and long term.

[1] CPT copyright 2025 American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.