Statement on Proposed 2027 CPT Codes and Medicare Payment Changes

SILVER SPRING, MD - The American Nurses Association (ANA) is aware of concerns surrounding changes under consideration through the Current Procedural Terminology (CPT) code process, led by the American Medical Association (AMA), and the 2027 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (HOPPS) proposed rules from the Centers for Medicare & Medicaid Services (CMS).

Nurses are right to expect that healthcare policy and payment decisions reflect the full value of nursing care and safeguard the role of professional nursing judgment. At this time, the AMA process for CPT codes and the CMS PFS and HOPPS proposed rules do not create artificial intelligence (AI)-related billing codes for nursing services, nor do they change how direct care nursing is financed. CPT codes describe services and procedures; they do not determine which health professionals may perform or bill for them. Typically, the AMA makes recommendations regarding CPT code reimbursement rates to CMS; CMS then decides how Medicare will reimburse for the services the CPT codes represent.

ANA firmly believes that nurses must help shape the development, deployment, and oversight of artificial intelligence in healthcare. Through its representation on the AMA's CPT and Relative Value Scale Update Committee panels, ANA reviews proposals that may affect nurses and patients. Further, ANA will submit comment letters on the proposed technology coding updates and other relevant provisions of the 2027 PFS and HOPPS before the public comment period for both rules closes.

AMA and CMS are working in parallel to ascertain how existing and new AI technologies should be reimbursed now and in the future, as the healthcare delivery system continues to adopt and invest in innovative tools that allow all practitioners to provide personalized care to patients for better health outcomes. This current work by AMA and CMS seeks to adopt a sustainable solution and framework for reimbursement for technology already in use by healthcare providers. In fact, CMS clearly states that the proposed changes in the HOPPS and PFS are temporary, allowing the agency to establish mechanisms for collecting more data and gathering stakeholder feedback as it works toward a stable, more permanent reimbursement framework that meets the needs of all practitioners and providers.

While none of the proposed changes currently directly affect nursing, ANA does share concerns that additional guardrails may be necessary to ensure any future code proposals related to nurses and healthcare procedures in general are aligned with the needs of patients and the nurses providing direct patient care.

ANA will continue to advocate with all stakeholders to ensure policies reflect, protect, and improve how nursing care is valued throughout the healthcare system.

About the American Nurses Association

As the preeminent organization representing more than 5 million nurses, the American Nurses Association stands at the forefront of advancing nursing excellence. The association harnesses The Power of Nurses® to champion the profession and drive transformation in healthcare. Through legislative and political advocacy, comprehensive educational services, and the profession's leading Code of Ethics and Scope and Standards, the association empowers nurses across every specialty and practice setting. The association is committed to ensuring healthy work environments, shaping pioneering policies, and cultivating partnerships that enhance both the nursing profession and the broader healthcare experience.

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