ANA Responds to Nurses’ AI Billing Concerns, Commits to Comment on Medicare Rules

The American Nurses Association has responded to nurses’ questions about proposed billing and payment changes for clinical artificial intelligence, releasing a statement on July 23 covering both the American Medical Association’s CPT code process and the federal government’s proposed 2027 Medicare payment rules.

The ANA’s central message is one of reassurance: according to the association, the current proposals “do not create artificial intelligence (AI)-related billing codes for nursing services” and do not change how direct care nursing is financed. At the same time, the statement commits the organization to formal action on both open federal rules and acknowledges that additional safeguards may be needed as AI-related coding evolves.

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The statement responds to questions nurses and nursing leaders have raised in recent weeks as the AMA develops proposed billing codes for clinical work performed by AI and Medicare moves to give clinical software its own named place in the payment system.

“Nurses are right to expect that healthcare policy and payment decisions reflect the full value of nursing care and safeguard the role of professional nursing judgment,” the statement reads.

The ANA’s position on the current proposals, in summary: they describe and pay for AI-related services, not nursing services, and nothing in them changes how nursing is paid for today. The association also notes that CPT codes describe services and procedures rather than determining which professionals may perform or bill for them, and that the AMA recommends payment values while CMS decides what Medicare actually pays.

“ANA firmly believes that nurses must help shape the development, deployment, and oversight of artificial intelligence in healthcare,” the statement continues. The association says it reviews proposals that may affect nurses and patients through its seats on the AMA committees that write the codes and recommend their values.

Two elements of the statement go beyond reassurance.

First, the comment letters: “ANA will submit comment letters on the proposed technology coding updates and other relevant provisions of the 2027 PFS and HOPPS before the public comment period for both rules closes,” the statement says. Those windows are:

• The hospital outpatient rule (CMS-1850-P, which the ANA refers to as HOPPS), containing the proposed Software as a Medical Service payment designation. Comments close August 31, 2026.
• The physician payment rule (CMS-1848-P, the PFS), which includes a request for public input on the current coding and valuation processes. Comments close September 14, 2026.

Both rules are open to comment from anyone through each rule’s Federal Register page.

Second, the guardrails: “While none of the proposed changes currently directly affect nursing, ANA does share concerns that additional guardrails may be necessary to ensure any future code proposals related to nurses and healthcare procedures in general are aligned with the needs of patients and the nurses providing direct patient care.”

The AMA and CMS are working in parallel on how AI-enabled clinical services should be paid for. The AMA’s coding panel is developing proposed codes for services performed by algorithms, and CMS’s 2027 hospital outpatient proposal would, for the first time, gather clinical software under one name in Medicare’s payment system. CMS describes its proposal as a temporary step while it collects data and feedback toward a permanent approach, a characterization the ANA’s statement echoes.

“ANA will continue to advocate with all stakeholders to ensure policies reflect, protect, and improve how nursing care is valued throughout the healthcare system,” the statement concludes.

The association represents the interests of the nation’s more than 5 million registered nurses.

For additional background, see Nurse.org’s in-depth coverage of AI billing and nursing reimbursement:

🤔 Nurses: What would you want the ANA’s comment letters to say on nursing’s behalf? Tell us in the comments below.