January 26, 2026
In response to payment changes stemming from CMS’ 2026 practice expense (PE) methodology updates, PALTmed is continuing its advocacy and education efforts focused on clinician reimbursement in skilled nursing facilities (SNFs) and nursing facilities (NFs). PALTmed has raised concerns that CMS’ revised methodology for calculating indirect PE RVUs, particularly reductions associated with facility-based care, does not fully reflect the delivery of medical services in post-acute and long-term care settings.
Key Actions PALTmed Is Taking
- Engaging CMS in targeted discussions to clarify the distinct clinical and regulatory responsibilities of post-acute and long-term care (PALTC) clinicians and to challenge CMS assumptions underlying the PE cuts, including misaligned practice expense inputs in nursing home settings. PALTmed continues to emphasize that these reductions do not reflect the real-world cost structure of independent PALTC practices, which bear the full burden of overhead costs because SNFs do not cover these expenses, contrary to CMS assumptions in both the proposed and final rules. PALTmed has called on CMS to immediately restore parity in PE valuation across nursing home settings to ensure that SNF patients do not lose access to this vital care.
- Coordinating with national stakeholder organizations across the PALTC continuum to share perspectives and align on areas of concern. These organizations have expressed similar concerns about the potential impact of the cuts on access to high-acuity, on-site medical care for SNF patients.
Educating members on accurate place-of-service (POS) coding in nursing homes. Under the revised payment structure, correct differentiation between POS 31 (SNF) and POS 32 (NF) has become increasingly important, as reimbursement is now more directly tied to whether a patient is in a Part A SNF stay or a non–Part A NF stay.
PALTmed’s educational materials, including its POS Made Simple one-pager and detailed breakdown of 2026 nursing home payment changes, clarify billing rules and impacts on E/M code payments.
PALTmed stresses that without corrective action, these PE changes risk worsening clinician shortages and undermining the ability of professionals to meet regulatory and patient care obligations in SNFs. To prevent further disruption, PALTmed is asking CMS to immediately take action on this important issue.
We urge you to share with PALTmed any anecdotes on how this change has affected your practice and access to care for your patients.