What April 2027 Does to Your 2023 Nursing Home Claims

CMS issued eight transmittals this morning. Seven of them do what transmittals do: move a rate, update a code set, revise an edit or a manual chapter.

The eighth reaches back into 2023.

Transmittal 13995, Pub. 100-04, directs the Common Working File to write a one-time utility across paid claims history. It walks every professional claim detail line with a date of service from May 11, 2023 through December 31, 2024, finds the ones billed with place of service 32 whose line dates fall within or overlap a posted Part A skilled nursing claim, and stamps them with an informational unsolicited response. Then the MACs reprocess them.

The instruction changes no manual section. It has zero attachments. And it carries one sentence that decides what this costs you:

"Contractors shall follow standard recoupment procedures for any resulting overpayments."

One Utility, 601 Days

The overlap test is mechanical. A Part B line with POS 32 on it, and a Part A SNF claim in history carrying bill type 21x, or a swing bed claim carrying 18x, covering the same dates.

Critical access hospital swing beds are excluded. Nothing else is.

POS 32 is the code for a nursing facility, or a skilled nursing facility where the patient has no Part A coverage. POS 31 is the one for a Part A stay.

When a practitioner puts 32 on the line and the Part A claim says otherwise, Medicare paid the non-facility rate for a service it owed the facility rate on, and the facility was paid for the same overhead.

The window runs 601 days. The effective date is April 1, 2027 and the implementation date is April 5, 2027, which is 179 days from today.

One footnote for anyone filing this: the transmittal index row on cms.gov prints the change request as 14682, and the document itself prints 14582 in its header and numbers both of its business requirements 14582.1 and 14582.2. Search on the transmittal number.