ANA Addresses AI Billing Frameworks Impact on Nursing

The American Nurses Association (ANA) has issued a statement addressing inquiries from the nursing community regarding the proposed billing and payment frameworks for clinical artificial intelligence (AI). Released on July 23, this update tackles the American Medical Association's (AMA) Current Procedural Terminology (CPT) coding process and the federal government's anticipated 2027 Medicare payment guidelines.

The ANA clarifies that the current proposals neither introduce AI-specific billing codes for nursing services nor alter the existing structure for financing direct nursing care. Although no immediate impacts are projected, the association highlights the necessity of ongoing involvement in federal regulatory processes and potential compliance measures as AI-related billing codes develop.

In recent weeks, the nursing sector has raised questions aligned with the AMA's development of billing codes for AI-assisted clinical functions. Medicare's consideration of recognizing clinical software distinctly within the payment framework has also been a focal point. The ANA stresses the importance of healthcare policy and remuneration decisions accurately reflecting the value of nursing care and preserving the critical role of professional nursing judgment.

Two primary assertions are made: AI service descriptions and payments are separate from nursing services, and the current proposals maintain the existing payment structures for nursing. CPT codes, designed to describe services and procedures, do not specify which professionals may provide or bill for them. Although the AMA proposes payment values, the Centers for Medicare & Medicaid Services (CMS) determine actual Medicare payments.

The ANA is committed to influencing the evolution, implementation, and oversight of AI in healthcare. Through participation in AMA committees, the association assesses relevant proposals and will submit formal comments on the 2027 PFS and HOPPS coding updates within their respective public comment periods. Feedback may be submitted via the Federal Register for each rule.

While current proposals do not directly impact nursing, the ANA expresses concerns about the need for protective measures to ensure future code proposals align with patient care needs and the contributions of direct care nurses. The AMA and CMS are developing frameworks for AI-enabled clinical services, with AMA crafting codes for algorithm-performed services and CMS's 2027 outpatient proposal categorizing clinical software under Medicare as a temporary approach.

The statement concludes with a commitment to continued advocacy, ensuring policies accurately reflect and enhance the nursing profession's contributions within the healthcare system. The ANA represents the interests of over 5 million registered nurses across the nation.