Comment on CMS-2026-2377-0002
Anonymous AnonymousOpposeIndividual
Summary: The commenter opposes the proposed CMAA billing codes because they believe the codes would allow hospitals to bill for AI-performed clinical work without human oversight. They argue that this creates a financial incentive to prioritize algorithms over human clinicians and could lead to medical errors.
I am writing to express concern about the proposed CMAA billing codes, which would allow hospitals to bill for clinical work performed entirely by Al, with no human clinician required at the point of care.
AI technology should be a tool that supports the people delivering care, not a
replacement that gets rewarded financially while the humans doing the work do not.
Creating a direct billing pathway for Al, without first establishing equivalent recognition and reimbursement for the clinical staff already providing that care, sends a clear incentive to hospitals: invest in the algorithm, not the person. That is backwards. The humans providing care are the ones who should be compensated first and foremost. Al should exist to support them, not to compete with them for hospital revenue.
I'm asking CMS not to finalize a payment pathway that rewards automated clinical work over the human care patients actually depend on. Furthermore, prioritizing automated algorithmic revenue over personalized human care will not improve patient outcomes. I have seen errors in AI generated notes and reports that could lead to incorrect treatments. Clinicians are not infallible but the likelihood of them catching these mistakes before they become a part of the patient’s treatment plan is higher if they wrote the words themselves vs. relying on AI.