Comment on CMS-2026-2377-0002
Deborah L. CantlinSupportIndividual
Summary: A Registered Nurse with 40 years of experience supports CMS's efforts to reform CPT code valuation and reduce the AMA's influence. The commenter advocates for an independent, multidisciplinary body to value codes and expresses concern over the safety and validity of AI-supported care codes.
I have been a Registered Nurse for 40 years and actively involved in promoting evidence-based, patient-centered-led Team Based Care. I am writing to support CMS's efforts to reform how CPT codes are valued, reducing the outsized influence the AMA and its RUC committee hold over payment rate-setting. I urge CMS to establish an independent, multidisciplinary body — including nurses and NPs — to work alongside the RUC in valuing codes, especially those tied to AI-supported care. Nurses have yet to be granted authority to use CPT codes for the various care provided by our unique practice: Patient education, health screening, chronic disease management, etc. The fact that AI CPT codes are being considered above Nurses long time efforts, is unacceptable. AI has no guardrails for safety and no validity supporting it's use. This puts our patients safety in jeopardy and futher stresses nurses, by adding extra layers of complexity to patient's care.