How One Nursing Home Visit Got Two Medicare Rates
The CY 2026 facility practice expense cut split nine nursing facility E/M codes by the beneficiary's Part A status, so the same visit pays two rates depending on who is covering the bed. We priced the gap at $423 million on CMS's own utilization weights. The CY 2027 proposal closes it for these nine codes and asks, in the same section, whether facility practice expense should go to zero for everyone else.
There is a moment in a nursing home stay when the visit starts paying more.
The patient does not move. The clinician does the same work, writes the same note, bills the same code.
What changes is that the Part A stay ends, the place of service goes from 31 to 32, and Medicare reprices the encounter.
In 2025 that flip was worth exactly nothing. Facility and non-facility paid the same on all nine nursing facility E/M codes, down to the RVU.
In 2026 it is worth $16.03 on 99309, the code carrying 18,245,940 allowed services a year.
"What is Medicare buying with the extra $16.03 when the only thing that changed is which part of the program is paying the bed?"
Nothing, per CMS. Which is why the CY 2027 physician fee schedule proposed rule takes it back.
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