Comment on CMS-2026-2377-0002
Marion LearySupportIndividual
Summary: Marion Leary, a nursing education professional, supports the proposed rule but argues that it should go further by creating specific billing codes for nursing work. She advocates for the recognition and reimbursement of nursing-led quality and safety improvements, which she claims are currently bundled into other clinician billing.
Re: CMS-1848-P — CY 2027 Medicare Physician Fee Schedule Proposed Rule
I am a Phd, MPH, RN with 21 years of experience working in nursing education. I am submitting this comment on the proposed rule above.
Nurses are STEM prepared experts in their fields. The care we provide is equal to any care provided by a physician and should be reimbursed as such.
Here is some of what my direct care has meant, in terms Medicare already measures. Under nurse-led quality and safety improvement: patients protected by safety processes nurses designed and ran. This is harm prevented before it happened: nursing assessment, judgment and intuition applied reliably, to every patient. Medicare measures and pays for these outcomes, yet the nursing work behind them is bundled into room-and-board or other clinicians' billing — invisible in claims data, ineligible for reimbursement, and absent from the quality metrics these programs use. I ask CMS to fix this misalignment and to build codes that let nursing work be seen, counted, and reimbursed.
Thank you for considering these comments.
Sincerely,
Marion Leary, Phd, MPH, RN
Nursing education