Nurses Waited a Century for Their Own Billing Codes — AI May Get There First (with Stephanie Witwer)

Nursing has never had its own CPT billing codes — but AI is about to get 288 of them. In this episode of the Love n' Leary Nursing Podcast, hosts Marion Leary and Rebecca Love sit down with Stephanie Witwer, PhD, RN, NEA-BC, FAAN, a leading ambulatory care nurse expert and strategic advisor to AAACN, to unpack the AMA's proposed AI CPT codes and what they mean for the future of nursing.

Stephanie explains how CPT codes work, why nursing work is billed as "incident to" physician services, and how $266 billion in annual nursing care remains invisible to payers. The conversation breaks down the three proposed AI categories — assistive, augmentative, and autonomous — and the legal, ethical, and economic risks of reimbursing AI while nursing stays unbillable. Could health systems be incentivized to invest in AI instead of nurses?

Most importantly: there's something nurses can do right now. A CMS public comment period is open, and the hosts are calling for 100,000 nurse comments to get concerns on the permanent public record.

Topics include: CPT codes explained, RVUs, incident-to billing, AI reimbursement, autonomous AI and nurse practice acts, nurse staffing economics, and how to submit a CMS public comment.

Jump Ahead:

• 00:58 – Welcome and episode overview: AMA's proposed AI CPT codes and the CMS comment period with Stephanie Witwer
• 03:07 – CPT codes 101: the 1960s origin, AMA ownership, and how they became the national billing standard
• 08:58 – Are there any CPT codes for nursing? (Spoiler: zero)
• 14:55 – Assistive vs. augmentative vs. autonomous AI, and the nurse practice act problem
• 16:53 – The economics: what AI reimbursement means for nursing jobs
• 20:05 – The call to action: a billing taxonomy for nursing, how to comment to CMS
• 23:03 – Closing thoughts: the power of a unified nursing voice

Resources:

• Comment on the CMS physician payment rule (CMS-1848-P, the PFS) by September 14, 2026.
• Comment on the CMS hospital outpatient rule (CMS-1850-P, which the ANA refers to as HOPPS) by August 31, 2026.
• Register and comment on the AMA CPT Editorial Panel Meeting Interested Party through August 10, 3036

For additional background, see Nurse.org's in-depth coverage of AI billing and nursing reimbursement:

• Nurses Have Waited a Century for Billing Codes. AI May Get Them First (7/16)
• Nurses Have Never Had Their Own Medicare Payment Designation. Software May Get One First (7/20)
• The Evolution of CPT Codes and Their Emergence as THE National Healthcare Billing Standard (7/22)

Becker's Healthcare coverage:

• New AI billing codes spark concern across nursing (7/17)
• Nurses’ AI pushback expands to new front (7/20)

The views, thoughts, and opinions expressed in this episode belong solely to the hosts and do not necessarily reflect the official policy, beliefs, or position of Nurse.org

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