HeartFlow

$15 (board probability 28%

the board files this as its short being RIGHT, tied to roughly 7x trailing sales — $191.42M x 7 = $15.54, rounded to $15). The final rule confirms APC 1510 at $850.50 and the market re-prices the payment pathway as a levelled toll rather than a rent: the plaque code is shared with the rival HeartFlow is suing, three Category III placeholders already sit at the identical rate, a second cleared device holds 75580's own product code, CMS has crosswalked other algorithms to 75580 as a public benchmark, and CMS has floated multiple-procedure discounting for exactly this class of service. If the ESTIMATED — and primary-UNVERIFIED (canon REG-CPT-013) — 50% MPPR on 75577 with 75574 is real, the second growth engine realises under $500 a study rather than $950.50. On that reading, 11.4x trailing sales on a business losing $111.83M compresses toward 7x, and the gap CMS has already published between the paid rate and measured cost — $950.50 against a CY2024 geometric mean of ~$496 — becomes the CY2028 conversation.

$22 (board probability 47%)

The final rule lands roughly as proposed: 75580 at $850.50 in New Technology APC 1510, a $26.84 or 3.06% cut no model breaks on. Volume keeps compounding at the guided +29-32% and defends most of the price, but the multiple drifts as investors re-read the code as a ceiling rather than a moat — the shared 75577, three placeholders at 75580's exact proposed rate, and CMS's interim-and-transitional language make the terminal rent harder to underwrite than it looked at IPO. The stock underperforms without breaking, and the argument moves to CY2028, the first cycle in which CMS has real 75577 claims data to set a rate from.

$37 (board probability 25%

the board files this as its short being WRONG). CMS uses its section 1833(t)(2)(E) equitable-adjustment authority to hold or restore 75580 — exactly what it does elsewhere in the same rule, holding 75577 at $950.50 against a CY2023 geometric mean near $180 and Optellum's 0721T/0722T at $650.50 where the data implied an approximate 90 percent reduction. With the ceiling intact, a business growing 29-32% at approximately 81% non-GAAP gross margin, ramping a second Category I code ahead of schedule and beating and raising each quarter, re-rates toward the $36.63 consensus; a ~25% float turns that into a squeeze rather than a drift. The optional kicker is structural — Medtronic just paid up to $585M for CathWorks, and a strategic bid for two Category I codes plus 1,800 institutions would settle the argument outright.

• The category's founding regulatory position plus a decade of evidence: FFRCT was granted through the De Novo pathway on 1 Dec 2014 (DEN130045), creating 21 CFR 870.1415 Class II product code PJA, then extended by 510(k) clearances for Plaque and Roadmap (Oct 2022) and Next Gen Plaque (Sep 2025). PRECISE (2,103 participants, 65 sites) and seven-year ADVANCE-DK outcomes (5.7% vs 16.2% adverse events) are data no console feature has
• Software economics improving fast — 80.2% GAAP gross margin from 75.1% a year earlier, ~81% non-GAAP guided. The gain is earned cost improvement and it is retained, because the sell-side price is fixed
• Growth that is fast, broad and beating — +41.3% in Q1 2026 on a +40% FY2025, a revenue beat, and guidance RAISED on both the top line and gross margin in the same release. Two Category I codes are ramping at once
• Distribution depth that is slow to rebuild — 1,800+ institutions, 650,000 patients served, 200 million annotated CCTA images, and company-disclosed FFRCT coverage policies at approximately 99% of US covered lives
• A funded balance sheet and an offensive legal posture — $254.9M of cash after a $364.2M gross IPO, funding both the operating loss and a six-patent suit against its closest private rival that the defendant must fund out of venture equity

• The selling price is not the company's to set — 75580 fell 13.77% in one year and is proposed down a further 3.06%, cumulatively -16.40% from the CY2025 peak, in a rule HeartFlow can comment on but not control
• The second code is shared, not owned. 75577 pays $950.50 flat across four vintages and Cleerly and any entrant bill it identically — the plaque ramp is a volume race inside a price CMS sets, with zero pricing exclusivity
• Persistently loss-making with no dated path to profit — FY2025 net loss $116.8M on $176.0M, TTM net loss $111.83M, Q1 2026 operating expenses at 136% of revenue, $25.3M of cash consumed in the quarter
• Concentration of the purest kind — essentially all revenue on two CPT codes, one payer's annual rulemaking cycle, one modality, and one country for over 91% of it. International grew slower (+26%) than the US (+41%) in FY2025
• A ~25% float from a 2025 IPO makes the equity mechanically volatile in both directions: the 52-week range spans 2.0x on a business whose fundamentals moved in one direction all year

• The plaque ramp itself — 75577 became Category I on 1 Jan 2026 with five of seven MACs at final LCD, and management says adoption is ahead of schedule. If the code is a volume permit rather than a rent, the vendor with the largest installed base and deepest image corpus wins the race
• CMS's equitable-adjustment authority cuts both ways, with a live precedent in the same rule: it held Optellum's 0721T/0722T at $650.50 where claims data implied APC 1502 and, verbatim, 'the resulting approximate 90 percent reduction in payment', overriding under section 1833(t)(2)(E) (canon REG-CPT-006)
• The base procedure is being paid more — CPT 75574 rises to a proposed $398.54 from $356.43, +11.8%. A payer expanding the scan is expanding HeartFlow's addressable study volume even while trimming the algorithm's rate
• Non-OPPS revenue the CY2027 rule does not touch — the UK, Japan and Canada run separate pathways, and US office and imaging-centre volume falls under the Physician Fee Schedule, a separate rule (CMS-1848-P, 91 FR 43842, comments close 14 Sep 2026; canon REG-CMS-013)
• Consolidation optionality now that the comparable has priced — Medtronic completed its CathWorks acquisition on 20 Apr 2026 for up to $585M. A ~$2.2-2.3B listed asset with two Category I codes and 1,800 institutions is a legible target for an imaging OEM or cardiovascular strategic

• The CY2027 OPPS final rule, EXPECTED on public display around 1 Nov 2026 and effective 1 Jan 2027 — an expectation from CMS's annual cadence, not a published date (canon REG-CMS-014). It decides whether 75580 lands at $850.50 in APC 1510
• Exclusivity decaying inside Addendum B rather than the preamble — X567T, X668T and X669T sit in APC 1510 at exactly $850.50, and CMS already used 75580 as a public crosswalk benchmark to price Vektor Medical's vMap (0897T) in the CY2026 final rule (canon REG-CPT-004, REG-CPT-011)
• CMS calls the whole regime temporary in its own words — 'this is an interim policy', 'we propose to use CY 2027 as a transitional period', six occurrences — with rates maintained by hand under section 1833(t)(2)(E) rather than standard rate-setting, and CY2028 the first cycle with real 75577 claims data (canon REG-CPT-007). A rate held by fiat can be released by fiat
• In the same section that creates the category, CMS solicits comment on 'whether a new status indicator with the same specification as status indicator T (Procedure or service subject to multiple procedure discounting) would provide more appropriate payment' — a discount floated at exactly the multi-algorithm session HeartFlow's two products create (canon REG-CMS-009)
• Non-exclusivity at the device level — KeyaMed NA's DEEPVESSEL FFR was cleared 1 Apr 2022 (K213657) under HeartFlow's own product code PJA — the classification HeartFlow's De Novo created became a competitor's on-ramp (canon REG-CPT-012). Add Medtronic-owned CathWorks in the cath lab, Cleerly and Elucid on the plaque code, and the OEMs at the console
• A published gap between paid rate and measured cost — $950.50 against a CY2024 geometric mean of ~$496 and a CY2023 mean of ~$180. When CMS applies standard rate-setting, the arithmetic does not point up