Mobile & SNF Wound Care: The Setting Least Affected

What CMS proposed. CMS proposes for CY2027 to equalize payment for nursing-facility E/M visits regardless of whether the beneficiary is in a Part A skilled-nursing-facility stay or a Part B nursing-facility stay, by setting the facility PE RVU equal to the non-facility PE RVU for CPT 99304-99310 (initial and subsequent nursing facility care) and 99315-99316 (nursing facility discharge management). This corrects an unintended payment differential created by the CY2026 policy that cut the indirect practice-expense allocation for facility-setting services to 50 percent. CMS states that a clinician’s resource costs for a bedside visit do not depend on the patient’s Part A status, so the two rates should be the same. Separately, CMS solicits comment on the facility/non-facility framework more broadly, including whether hospital-employed physicians should receive a 50 percent, or even 0 percent, indirect PE allocation, and whether a new HCPCS modifier should identify employed physicians.

Sources: CY2027 PFS proposed rule (CMS-1848-P), §II.B(d) (site-of-service PE differential) and §II.C (telehealth). See the full rule.

The SNF E/M equalization

Under PFS payment rules, the same bedside visit in the same building can be paid at two different rates depending on the patient’s coverage status. A visit to a patient in a skilled nursing facility during a Part A stay (place of service 31) is treated as a “facility” service, while a visit to a patient in a Part B nursing-facility stay (place of service 32) is treated as “non-facility,” per the Medicare Claims Processing Manual, Chapter 12, Section 20.4.2.¹ The line CMS draws is the beneficiary’s Part A versus Part B status, not length of stay; this analysis uses “long-stay” as clinical shorthand for the Part B residents (POS 32) who fill much of the non-facility category. Before CY2026, this distinction did not matter for nursing-facility E/M: the facility and non-facility rates were equal.

The CY2026 final rule changed that, by accident. CMS finalized a policy allocating only half the indirect PE RVUs per work RVU to facility-setting services compared with non-facility services, intending to reflect that many facility-based clinicians no longer maintain independent office practices.² As intended, the change shifted PE RVUs from the facility setting to the non-facility setting. But for nursing-facility visits, the facility/non-facility label turns on the beneficiary’s Part A status, not on the setting of care itself. The result: the identical visit to the identical bed began paying less when the patient happened to be in a Part A stay.³

CMS calls this an “anomaly” and proposes to fix it for CY2027 by setting the facility PE RVU equal to the non-facility PE RVU for CPT 99304-99310 and 99315-99316: initial nursing facility care, subsequent nursing facility care, and nursing facility discharge management.⁴ The equalized rate is the non-facility (POS 32) rate: CMS sets the facility (POS 31) PE RVU up to meet it, not to a midpoint. Relative to CY2026 rates, this is a rate increase for POS 31 visits. What returns is the Part A/Part B parity that existed before CY2026, not the pre-CY2026 rate level itself, because the CY2026 reallocation had already lifted the non-facility rate that now serves as the common rate.

Alongside the proposal, CMS opens a wide-ranging comment solicitation on the facility/non-facility binary itself. It asks how practice-expense costs actually vary for clinicians employed by hospitals or health systems, whether the current 50 percent indirect PE allocation for facility services is accurate for hospital-employed physicians or should be lower (“such as 0 percent”) and whether a new HCPCS modifier for employed physicians could be used to identify and reduce facility PE on their claims.⁵ These are questions, not proposals, but they signal where CMS may go in future rulemaking.

Why mobile & SNF wound care is comparatively less affected

Set against the rest of the CY2027 proposed rule, nursing-facility and home-based wound care is comparatively sheltered, and in some respects directly helped.

First, the proposed modifier -25 payment reduction applies only to office/outpatient E/M codes.⁶ Nursing-facility E/M codes (99304-99310, 99315-99316) are not on the list, so a wound-care clinician who performs a debridement and a separately identifiable E/M visit at the bedside would not see the same-day E/M payment cut that office-based practices face under this proposal.

Second, the regulatory impact analysis shows facility-setting specialties skewing positive: nurse practitioners at +6 percent, geriatrics at +7 percent, and family practice in the facility setting at +3 percent. These are the specialty profiles that dominate SNF and mobile wound care, and the NF E/M equalization is part of what drives those figures.

One asymmetry runs the other way: the proposed MOD1, the 16 percent visit-complexity modifier replacing HCPCS G2211, covers office/outpatient and home or residence E/M (including 99341-99350) but not nursing-facility codes.⁷ A mobile clinician seeing a patient at home can append MOD1 to the visit; the same clinician seeing a comparable long-stay patient in a nursing facility cannot. SNF-based practices gain from the equalization but are excluded from the complexity adjustment that office and home-based visits can carry.

Telehealth: modest changes

The CY2027 telehealth section contains no proposal that specifically restricts or expands nursing-facility telehealth E/M. CMS received no requests to add or remove services from the Medicare Telehealth Services List for CY2027, and proposes to add a handful of new G-codes (advance care planning, group medical sessions, pediatric speech-language treatment, and vaccine adverse-effect visits).⁸⁹ CMS also proposes revised descriptors for the telehealth critical-care consult codes G0508 and G0509 (restating them in time-based terms after the CY2026 final rule permanently removed the once-per-day frequency limit¹⁰) and a modification to teaching-physician virtual-presence policy allowing billing when either the teaching physician or the resident is physically with the patient.¹¹ The telehealth originating-site facility fee (Q3014) would update to $32.65 for CY2027 under a proposed 2.5 percent MEI increase.¹²

For SNF and mobile wound-care practices, the practical effect is stability: the statutory flexibilities extended by the Consolidated Appropriations Act, 2026 (geographic and originating-site flexibility through December 31, 2027; audio-only through January 1, 2028) continue to govern, and nothing in this rule changes how nursing-facility telehealth E/M is paid or how often it may be furnished.

Why it matters for wound care

Chronic wounds are concentrated exactly where this rule helps most: among frail, often bedbound patients in nursing facilities and private homes. A wound-care clinician rounding in a SNF typically sees a mix of Part A patients (post-acute stays, POS 31) and long-stay Part B residents (POS 32) in the same hallway on the same day. In CY2026, that clinician has been paid less for the Part A patients than for the Part B patients, for identical work. The CY2027 proposal removes that differential and restores a single rate.

Combined with the sparing of nursing-facility E/M from the modifier -25 cut and the positive facility-setting impact estimates, the net effect is that CMS’s CY2027 restructuring lands lightest, and in some places as a net increase, on bedside wound care delivered outside the office. Under this proposal, the payment environment for SNF and home-based wound care improves relative to office-based settings.

Deep-dive: implications by practice model

Office-based wound care

An office-based wound care practice sees little of this benefit. The NF E/M equalization applies only to nursing-facility codes, so a practice billing office/outpatient E/M (99202-99215) gains nothing from it. Meanwhile the same practice absorbs the proposals that weigh on office settings: the modifier -25 reduction targets office/outpatient E/M billed same-day with procedures (the routine debridement-plus-visit pattern), and the office-based specialty impacts in the RIA are correspondingly lower than the facility-setting figures. The one office-side positive in this cluster is MOD1 eligibility: office/outpatient E/M can carry the 16 percent complexity modifier when the practice serves as the continuing focal point for the patient’s care.

For office-only wound practices, the equalization has no direct effect: it applies to nursing-facility codes that an office practice does not bill. The broader pattern is that the CY2026-2027 practice-expense restructuring affects facility-setting and home-based E/M less in this rule than office-based E/M, so an office practice’s principal financial exposure in this cluster sits with the modifier -25 proposal rather than with anything on this page.

Mobile wound care

Mobile and traveling providers deliver wound care wherever the patient lives, from private homes to skilled nursing facilities. This page’s SNF equalization is the clearest example of the SNF setting being less affected, so the two halves of the mobile route are broken out below.

Home & residence

Mobile practices that see patients in private homes bill home/residence E/M (99341-99350), which sits in the least-exposed position in this rule: those codes are untouched by the modifier -25 proposal and are explicitly within MOD1’s descriptor, so a mobile clinician serving as a homebound patient’s continuing focal point of care can append the 16 percent complexity modifier. Mobile groups that also round in nursing facilities get the POS 31 equalization on top. The facility-setting RIA impacts (+6 percent for nurse practitioners, who staff much of mobile wound care) point in the same direction.

Mobile wound care is comparatively well positioned under this rule: MOD1 eligibility on home visits, no -25 exposure on E/M in the home, restored POS 31 parity for the SNF portion of the route, and positive specialty-level impacts. The main caveat is the seam between the home and the facility: the same clinician loses MOD1 eligibility when the visit moves from a residence to a nursing facility, despite comparable longitudinal complexity, so the net effect for a mobile group depends on its mix of places of service.

Skilled nursing facility

SNF-based practices see the clearest relative gain. The equalization restores the POS 31 rate to parity with POS 32 for the entire nursing-facility E/M family they bill daily (99304-99310 and 99315-99316), reversing the CY2026 cut for Part A patients. Their codes are spared from the modifier -25 reduction, so procedure-plus-visit days at the bedside are unaffected by that proposal. And the RIA’s facility-setting impacts (nurse practitioners +6 percent, geriatrics +7 percent) describe exactly this workforce. The gap: nursing-facility E/M is outside MOD1, so the longitudinal-complexity payment available for office and home visits is not available at the SNF bedside.

For SNF-based wound care, the equalization restores POS 31 parity while the MOD1 exclusion of nursing-facility codes cuts the other way, and the two rest on the same clinician-resource-cost logic. CMS’s rationale for the equalization is that clinician resource costs do not vary with a patient’s Part A status; the same reasoning would appear to apply to the complexity modifier, since the long-stay nursing-facility resident with chronic wounds fits the single, serious, or complex condition MOD1 describes and the clinician rounding weekly functions as a continuing focal point of care. As proposed, however, that longitudinal-complexity payment is available for office and home visits but not at the SNF bedside.

Wound care center

Hospital-affiliated wound care centers are largely bystanders to the NF E/M equalization, but the surrounding comment solicitation bears directly on their model. CMS is asking whether hospital-employed physicians truly incur the indirect practice expenses the PFS pays them for, whether the facility indirect PE allocation should fall below 50 percent, possibly to 0 percent, for employed physicians, and whether an “employed physician” HCPCS modifier could identify and reduce facility PE on their claims. None of that is proposed for CY2027, but it is aimed squarely at the employed, facility-based model many wound care centers use.

The equalization itself is neutral for centers; the more consequential item on this page for them is the employed-physician comment solicitation. If CMS were eventually to reduce or zero out indirect PE for hospital-employed physicians, the professional-fee economics of the employed wound-care-center model would deteriorate meaningfully. CMS has stated that the record on the indirect costs employed physicians actually bear (coding, billing, scheduling, and program administration) lacks consensus, so the data submitted in this comment cycle is likely to shape how any future proposal on this question is framed.

Considerations for providers and manufacturers

Each point below states what CMS proposed and then what it would mean in practice. These are analytical implications, not recommendations; some stakeholders may also weigh them when deciding whether to submit input during the public comment period.

• Equalization is a direct pay increase on Part A (POS 31) visits. CMS proposes to set the facility PE RVU equal to the non-facility rate for 99304-99310 and 99315-99316, undoing a CY2026 side effect that had made an identical bedside visit pay less for a Part A patient (POS 31) than a Part B patient (POS 32). For a mobile provider, POS 31 rounds are restored to parity (a straightforward payment increase on that volume), and the change removes the need to track a patient’s Part A status just to predict payment for the same clinical service.

• The SNF advantage exists only while NF codes stay outside the -25 cut. Because the modifier -25 reduction as drafted spares nursing-facility E/M, a bedside debridement plus a same-day NF visit is currently paid in full on both lines, unlike the office equivalent. That differential holds only while NF codes remain excluded. The same “resource costs don’t vary” logic CMS uses to equalize NF pay could later be used to pull NF into the reduction, so the exclusion is a feature of the current draft rather than a settled policy (see E/M & Modifier -25).

• MOD1 pays for complexity by site of service, not by actual complexity. The new modifier covers office/outpatient and home/residence E/M but not the 99304–99310 nursing-facility family. A clinician delivering longitudinal, high-complexity care to a long-stay resident with chronic wounds (arguably more complex than an office visit) cannot bill the 16% add-on for it, while the same clinician’s home-visit and office patients can. The result is that the complexity payment turns on where care is delivered rather than how complex it is, disadvantaging the SNF-based line specifically.

• A broadly written employed-physician PE rule could catch independent groups. CMS is exploring reduced (or zero) indirect practice expense for hospital-employed physicians, possibly via an “employed physician” modifier. If a future version is drafted broadly, it could sweep in facility-based independent practices that do carry real indirect costs (travel, scheduling, billing, bedside supplies) and cut their PE even though they are not hospital-employed. How narrowly any such policy is drawn would likely depend on the indirect-cost data for independent rounding groups in the rulemaking record.

The public comment period is open through September 14, 2026 (docket CMS-2026-2377). See How to Comment for the mechanics.

Footnotes

1. Proposed rule §II.B(d), Updates to Practice Expense (PE) Methodology: Site of Service Payment Differential (CMS-1848-P, 91 FR 43860). CMS states:
   “For purposes of PFS payment, a service furnished to a patient in a skilled nursing facility during a Part A hospital stay (place of service 31) is considered to be in the “facility” setting, while a service furnished to a patient in a Part B stay (place of service 32) is considered to be in the “non-facility” setting, per the Medicare Claims Processing Manual (MCPM), Chapter 12, Section 20.4.2 […]”

2. Proposed rule §II.B(d), Updates to Practice Expense (PE) Methodology: Site of Service Payment Differential (CMS-1848-P, 91 FR 43859). CMS states:
   “Under the finalized policy, we allocate half the amount of indirect PE RVUs per work RVU for services furnished in the facility setting compared to those allocated to services furnished in the non-facility setting. […] This presumption was initially made in the context of most practitioners maintaining office practices independent of the facilities in which they provided care, and as we discussed in the CY 2026 PFS proposed and final rules, appears to be inconsistent with contemporary trends in physician practice where some significant portion of services furnished in facility settings are performed by medical practitioners who do not maintain fully independent practices and are less likely to incur a comparable amount of indirect costs.”

3. Proposed rule §II.B(d), Updates to Practice Expense (PE) Methodology: Site of Service Payment Differential (CMS-1848-P, 91 FR 43860). CMS states:
   “Prior to CY 2026, the payment rate for these E/M services furnished in a skilled nursing facility (“facility”) and a nursing facility (“non-facility”) were equal. As intended, the 50 percent reduction to the allocation of indirect PE based on work RVUs that we finalized for CY 2026 shifted PE RVUs from the facility setting to the non-facility setting. However, for nursing facility and skilled nursing facility visits, the current site of service differential is determined based on the status of the beneficiary (that is, a Part A versus Part B stay) in that setting, rather than in the setting of care itself.”

4. Proposed rule §II.B(d), Updates to Practice Expense (PE) Methodology: Site of Service Payment Differential (CMS-1848-P, 91 FR 43860). CMS states:
   “Given that the resource costs for the professional involved in furnishing an E/M service would not be expected to differ based on whether the patient is in a Part A stay or not, we believe it is more accurate for these E/M services to be paid the same amount without regard to the beneficiary’s Part A status. Therefore, we are proposing to address this anomaly for CY 2027 by equalizing the rate for nursing facility visits without regard to the beneficiary’s status by setting the facility PE RVU equal to the non-facility PE RVU for CPT codes 99304 […] and 99316 (Nursing facility discharge management; more than 30 minutes total time on the date of the encounter).”

5. Proposed rule §II.B(d), Updates to Practice Expense (PE) Methodology: Site of Service Payment Differential (CMS-1848-P, 91 FR 43861). CMS states:
   “We are seeking comment on the amount of indirect PE hospital-employed physicians incur when they furnish care within a facility. For these physicians, is the 50 percent indirect PE allocation accurate or could it possibly be less than 50 percent, such as 0 percent? […] Specifically, we are seeking comment on whether a new HCPCS modifier for employed physicians would be a reasonable way to identify and reduce facility PE from the services they perform in the facility setting, or whether there are other methods we could consider.”

6. Proposed rule §II.D(58), Accounting for E/M Resource Overlap Between Stand-Alone Visits and Global Periods (CMS-1848-P, 91 FR 43908). CMS states:
   “We are proposing to reduce payment, as described later in this section, when a separately identifiable O/O E/M visit is furnished by the same physician (or a physician in the same group practice) on the same day as a 0-, 10-, and 90-day global procedure. […] While we are proposing to apply this policy only to O/O E/M visits, we are seeking comments on whether it should also apply to other E/M visits, such as inpatient E/M visits.”

7. Proposed rule §II.D(53), Evaluation and Management (E/M) Visit Complexity Add-On (HCPCS Code G2211) (CMS-1848-P, 91 FR 43899). CMS states:
   “We are proposing to match the code descriptor for HCPCS code G2211 to MOD1, with some technical changes. The new proposed modifier descriptor is: Visit complexity inherent to new or established office/outpatient or home or residence evaluation and management service, associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. […] Therefore, we are proposing a modifier to replace HCPCS code G2211 with the valuation of 16 percent of the base E/M code.”

8. Proposed rule §II.C, Payment for Medicare Telehealth Services (CMS-1848-P, 91 FR 43863). CMS states:
   “We did not receive any requests to add or remove services from the Medicare Telehealth Services List for CY 2027.”

9. Proposed rule §II.C, Payment for Medicare Telehealth Services (CMS-1848-P, 91 FR 43863). CMS states:
   “We are proposing to add HCPCS G-codes GACP1 (Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), first 20 minutes […]), GACP2 […], GSMAS (Voluntary, group-based medical session involving multiple patients with common medical condition(s), receiving medical care in a group setting […]), GSLPP (Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual; for the pediatric population up to age 18 or 21), and GADV1 (Office or other outpatient evaluation and management service(s) for the diagnosis and treatment of vaccine adverse effects, new or established patient […]) to the Medicare Telehealth Services List. If finalized, these services will be separately payable under the PFS.”

10. Proposed rule §II.C, Payment for Medicare Telehealth Services (CMS-1848-P, 91 FR 43864). CMS states:
    “Since the permanent removal of the frequency limitation of one critical care consultation service furnished via telehealth per day, we have received questions about language in the code descriptors for HCPCS codes G0508 […] and G0509 […] describing “initial” and “subsequent” consultations, as well as questions regarding the language about the typical time spent on the service. To clarify the requirements for billing these services, we are proposing the following revised code descriptors: G0508: Telehealth consultation, critical care; first 30 to 74 minutes. G0509: Telehealth consultation, critical care; each additional 30 minutes (List separately in addition to code for primary service).”

11. Proposed rule §II.C, Payment for Medicare Telehealth Services (CMS-1848-P, 91 FR 43864). CMS states:
    “For CY 2027, we are proposing a modification to our previously finalized policy. Rather than requiring the teaching physician, resident, and patient to each be in a different location, we are proposing to allow teaching physicians to bill for services involving residents when either the teaching physician or resident is in the same physical location as the beneficiary.”

12. Proposed rule §II.C, Payment for Medicare Telehealth Services (CMS-1848-P, 91 FR 43865). CMS states:
    “The proposed percentage increase in the MEI for CY 2027 is 2.5 percent and is based on the expected historical percentage increase of the 2017-based MEI. […] Therefore, for CY 2027, the proposed payment amount for HCPCS code Q3014 (Telehealth originating site facility fee) is $32.65.”