How a Therapy Cleanup Stops Paying for Wound Care
CR 14561 calls it an administrative correction of therapy codes. It pulls 45 codes off the only list that makes them separately payable during a covered Part A SNF stay on October 1, and $10.6 million of the $11.2 million riding on those codes is wound care.
Page three of a routine quarterly code update carries a heading CMS italicized and called an Administrative Note. Under it: these codes "were erroneously included in both the Part B SNF CB File #1 and the Part B SNF CB File #4."
Transmittal 13881 went out on August 21. It carries Change Request 14561, the October refresh of the HCPCS codes that drive skilled nursing facility consolidated billing edits, and most of it is what those updates always are.
Seven codes added to the Part A file. One added to a Part B file. Six short descriptors revised.
Then requirement 14561.10 removes 45 codes from Part B SNF CB File #1, effective October 1, 2026.
CMS calls that a correction. Your MAC will run it as an edit.
What File #1 Actually Is
Two of the four Part B SNF files are exclusion lists. The other two do the opposite job, and CMS's file explanation is blunt about what happens when a code falls off one of the first two:
"If the code is not found in either of these two files, the service is subject to SNF consolidated billing and the physician, non-physician practitioner, or supplier must look to the SNF for payment of the service. The MAC will not pay the service."
File #1 is the big exclusion list, 8,774 unique codes in the January 2026 release, all separately billable to the Part B MAC for a beneficiary in a covered Part A stay. File #2 is the professional-component list, the modifier 26 services, 1,138 codes.
File #4 is an inclusion list. It names therapy codes that are bundled, and it applies to the other kind of stay: the Part B non-covered one, where the Part A benefit is exhausted.
A code sitting on both #1 and #4 is therefore doing two coherent things at once. Separately payable in one stay type, bundled in the other.
CMS has decided that for these 45 it was an error anyway.
So we pulled both current files.
All 45 of 45 are on File #1 today. None of them is on File #2.
That closes it. On October 1 these codes lose the only route they had to separate payment during a covered Part A stay.
The rest of this brief is for subscribers.
The impact tables, the code-level detail, and the rest of the analysis sit past this line.
$50 a month, or $500 a year.
Already a subscriber? Sign in