How One Asterisk Decides Who Bills a Nursing Home Debridement
CMS has printed the same asterisk legend on its SNF therapy bundling file every year since 2020 and marked nothing with it. The CY 2026 file marks 49 of 107 codes, the marks say bundling now turns on who furnished the service, and the CWF edit that enforces the list only knows codes.
Every annual SNF consolidated billing therapy file since 2020 has carried the same sentence in its header: codes marked by an asterisk are only subject to consolidated billing when provided by a therapist.
Six of those files marked nothing. Not one code, not once, across CY 2020, 2021, 2022, 2023, 2024 and 2025.
The CY 2026 file marks 49 of its 107 codes (chart below).
"If the bundling rule now depends on who furnished the service, what is the claims edit supposed to do with a code?"
Seven Files, One Asterisk
You know File #4 from the last two times the desk opened this drawer. It is the inclusion list, the one that says these codes "are subject to SNF consolidated billing and must be billed through the SNF," and it governs the Part B non-covered stay, where the Part A benefit is spent and the resident is still in the building.
In August we ran CR 14561 pulling 45 codes off File #1, and in September the 44-code overlap between File #1 and File #4 that CMS cleared on October 5.
Neither post touched the asterisk column, because through CY 2025 there was nothing in it.
The list itself has grown slowly and unremarkably, 82 codes to 107 over seven years. The marks arrived all at once.
Worth knowing where they arrived from: the CY 2026 zip was last written on September 11, 2026, eight months into the year it governs, and the Part B MAC Update page stamps the same date. The CY 2025 file was posted December 26, 2024, before its year started, which is what the manual actually requires.
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