September 8, 2026
In its proposed 2027 Medicare Physician Fee Schedule, the Centers for Medicare & Medicaid Services (CMS) has signaled it wants to close the pay differential between place of service 31 and 32 by equalizing practice expense payment for nursing facility visits, regardless of whether a resident's stay is covered under Medicare Part A. It's a meaningful shift, and one grounded in a simple truth. The clinical work, resources, systems, and overhead needed to care for nursing facility residents don't change based on a patient's Medicare coverage status. Seeing a skilled nursing facility (SNF) patient shouldn't come with a pay cut.
The proposal is just that, a proposal. It won't take effect unless CMS finalizes it, and the agency needs to hear from the clinicians who live with this policy every day. Comments from members who understand how POS 31 payment affects PALTC practices and patient access carry real weight in the rulemaking process.
Use this simple tool that walks you through submitting a comment to CMS. You'll be able to generate a unique letter that you can review, customize, and personalize. Adding your own firsthand examples is what makes these comments effective, showing CMS exactly how the policy affects clinicians, practices, and the residents we serve.
The deadline is September 14. Comments must be submitted by then to be counted.
Member advocacy is what brought CMS to this point. Finishing the job means making sure the agency follows through, protects access to high-quality care for vulnerable residents, and restores a more equitable reimbursement policy for PALTC providers.