Valar Labs, Inc. supports the proposal to establish separate payment classifications for Software as a Medical Service (SaMS) but requests that their specific CPT codes be crosswalked to the New Technology APC 1509 payment amount. They also argue that their tests should remain billable by a CLIA-certified independent laboratory rather than being restricted to physician billing.

Anna Bazil, a registered nurse, supports the proposed rule but urges CMS to ensure AI safety and protect nurse staffing levels. She advocates for the creation of specific codes to recognize and reimburse nursing work that prevents patient harm, which is currently bundled into other billing categories.

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.

The commenter argues that the current reimbursement structure for AI-assisted care favors technology vendors and hospital margins over the clinical workforce. They propose that CMS should require transparency on how AI-related reimbursements are allocated and potentially condition a portion of that funding on demonstrable investments in clinical staffing and training.

The commenter argues that the current reimbursement structure for AI-assisted care favors technology vendors and hospital margins over the clinical workforce. They propose that CMS should require transparency on how AI-related reimbursements are allocated and potentially condition a portion of that funding on demonstrable investments in clinical staffing and training.

The commenter argues that current Medicare CPT and coverage structures create administrative bottlenecks by requiring physician co-signatures for AI-driven clinical actions that are primarily executed by nurses. They request that CMS acknowledge this gap, fund a study on expanding nursing scope for AI-supported actions, and consider pilot pathways for nurse-led implementation of AI alerts.

The commenter opposes the proposed CMAA billing codes that would allow hospitals to bill for clinical work performed entirely by AI. They argue that these codes create a financial incentive to prioritize algorithms over human clinicians, which they believe will erode patient outcomes.

The commenter opposes the creation of a specific billing code for AI in hospitals, arguing that it would lead to the replacement of human medical staff with technology. They express concern that AI lacks the nuanced judgment of human providers and that prioritizing cost-saving over human care will negatively impact patient outcomes.