Comment on CMS-2026-2377-0002
Lulette InfanteSupportIndividual
Summary: Lulette Infante, a nurse consultant and administrator, supports the proposed rule but urges CMS to create specific codes that recognize and reimburse nursing work. She argues that nursing contributions to patient safety and quality are currently invisible in claims data and should be explicitly accounted for.
Re: CMS-1848-P — CY 2027 Medicare Physician Fee Schedule Proposed Rule
I am an MSN, RN-BC, CPHQ with 30 years of experience working in nursing administration. I am submitting this comment on the proposed rule above.
Nurses have long been there for patients and families, including your own, and maybe even you someday. Allow us to do what we do best in taking care of you and your loved ones by honoring the value we bring to the hospital, not allowing AI to be there first when we have been doing this work for years- actually 30 years for me.
Here is some of what my direct care has meant, in terms Medicare already measures. Under nurse-led quality and safety improvement: dozens of patients protected by safety processes nurses designed and ran (As a Nurse consultant, I have developed initiatives to support and guide nurses in improving the care they provide to patients, including lowering infection rates by ensuring a safe labor and delivery environment and severe maternal morbidity by improving team communication). 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,
Lulette Infante, MSN, RN-BC, CPHQ
Nurse Consultant/Administrator