New billing codes would let hospitals charge for clinical AI analysis, raising concerns from nurses

• The AMA is developing CMAA billing codes that would let hospitals charge Medicare for clinical analysis performed entirely by AI, with no physician at the point of care.
• Bedside nursing, roughly 30 percent of hospital labor spending, still has no billing codes of its own, and nurses warn the ROI math will favor algorithms over staffing.

The American Medical Association is developing a new class of billing codes that would let hospitals charge for clinical analysis performed by an algorithm, with no physician at the point of care. Bedside nursing, meanwhile, has had no billing codes of its own and instead been folded into the room-and-board charge for nearly a century.

The AMA’s proposed framework, tentatively called Clinically Meaningful Algorithmic Analyses, or CMAA, would cover services in which software analyzes clinical data — medical images, lab results, heart-rhythm signals — and produces a medically actionable output without traditional physician work. It builds on Appendix S, the AMA’s 2021 taxonomy that classifies clinical AI as assistive, augmentative, or autonomous. The CPT Editorial Panel held its first formal discussion of the framework in September 2025 and sharpened the underlying definitions this spring.

The CPT 2026 code set, effective January 1, already added AI-enabled codes for services such as coronary plaque analysis and algorithmic ECG interpretation. As of January, 26 CPT codes existed for clinical AI, three of them Category I, the rest temporary Category III.

In early July, the agency’s proposed 2027 outpatient rule floated a temporary payment category for clinical software it now wants to call “Software as a Medical Service,” complete with a new status indicator and dozens of designated HCPCS codes. CMS says the old “Software as a Service” label reads like generic cloud computing, and it wants these treated as clinical services.

However, no CMAA codes exist yet, and a CPT code is not a guarantee of payment. Clinical AI still lacks a clear Medicare benefit category, but the architecture is now being built.

Why nursing is invisible in the billing math

For a century, nursing has been priced roughly the way a hotel prices housekeeping. The hospital bills for the bed and the nurse comes with it. The Commission for Nurse Reimbursement reviewed price-transparency data from a single academic medical center with more than 1,000 beds and found 158,475 billable line items, and not one inpatient nursing charge.

By the Commission’s analysis, nurses account for about 30 percent of hospital labor spending, roughly $266 billion a year, booked entirely as cost and never as revenue. Advanced practice nurses — nurse practitioners, CRNAs — can and do bill under CPT codes. Bedside RN care is the piece with no billing pathway at all, and the handful of exceptions only underscore how narrow the openings are. A 2025 Oregon law lets RNs seek Medicaid reimbursement on their own, but only for outpatient care coordination and only for patients without a primary care provider, not for inpatient bedside work. North Carolina has floated the idea at the recommendation stage. Neither touches the inpatient care that makes up the bulk of that $266 billion.

The standard objection to nursing codes has always been that the work is too continuous and too interwoven to break into billable units. CMAA is, in effect, the AMA solving that same problem for software.

Capital follows the billable

Rebecca Love, founder of the Commission for Nurse Reimbursement, frames the risk directly: once AI is a billable line item and nursing stays a fixed cost, the ROI math tilts toward buying more algorithms rather than hiring more nurses.

“If the AMA can build an entirely new billing category for AI, it can build one for nursing,” said Rebecca Love, Founder of the Commission for Nurse Reimbursement. 

“For decades, health systems have been told nursing work is too complex to unbundle nurses from the room rate and bill. However, the very process used to develop AI’s CMAA codes allows us to develop a CMAA equivalent for nursing. We must act now, for if we don’t, AI will be reimbursed for the very work nursing has long done but was never able to bill for. Nursing will remain a cost, AI will become a revenue stream, and the implications will be devastating to nursing.”

What to watch

The AMA’s written-comment window closes August 10, and CMS’s 2027 payment rule is open for public comment into mid-September.