Medicare Will Recheck Nursing Home Visits Billed With POS 32 in 2023 and 2024. Overpayments Will Be Taken Back.

Most practices treat a nursing home visit from 2023 as closed business. The claim was paid, the money was posted and the patient may have moved on. CMS has now said it will look at some of those claims again.

On October 8, 2026, CMS issued change request 14582 (Transmittal 13995). It tells Medicare's Common Working File to run a one-time check on Part B claims with dates of service from May 11, 2023 through December 31, 2024. The check looks for claim lines billed with place of service (POS) 32 whose dates fall inside a covered Part A skilled nursing facility (SNF) stay or a swing bed stay, excluding critical access hospital swing beds. Medicare administrative contractors (MACs) will then reprocess those claims and recoup any overpayment through their standard procedures. The change is effective April 1, 2027, with implementation on April 5, 2027.

Why one place-of-service code matters

CMS's rule for practitioners who see patients in nursing homes is short:

• POS 31 (skilled nursing facility) is used when the patient is in a SNF stay covered by Medicare Part A.
• POS 32 (nursing facility) is used in a nursing facility, and in a SNF once the patient's Part A coverage has been exhausted.
• In a mixed facility, with both nursing facility and SNF beds, POS 31 is used unless the physician can verify that Medicare will make no Part A payment.

CMS calls POS 32 the non-facility code. When a practitioner reports POS 32 for a patient who is actually in a Part A SNF stay, Medicare can pay the higher non-facility rate instead of the lower facility rate. In a May 2023 report, the HHS Office of Inspector General (OIG) found that Medicare overpaid about $22.5 million on more than 1.1 million claim lines in 2019 and 2020 this way, and that Medicare's systems had no edit to catch it. CMS agreed to recover the money, educate practitioners and add the edit.

What is already in place, and what is new

The edit for current claims arrived first. Under change request 13767, effective July 1, 2025, Medicare rejects a new POS 32 professional claim that overlaps an already processed Part A SNF stay. If the POS 32 claim was paid first and the SNF claim posts later, Medicare starts an adjustment of the professional claim.

Change request 14582 reaches back further. It applies the same overlap check to claims from May 11, 2023 through December 31, 2024, and says it expands on the earlier instruction. CMS doesn't explain why the window starts on May 11, 2023. What it does say is that the resulting overpayments will be recovered using standard recoupment procedures. For a practice, that usually means adjustments and offsets on future remittances rather than a single letter.

Who should look first

Any practice that bills Medicare for visits or procedures in nursing homes has some exposure: primary care and geriatrics groups, SNF hospitalist groups, psychiatry, podiatry, wound care, and nurse practitioner practices that round in facilities. The risk is highest where staff picked one POS code per facility and never changed it, or where nobody told the practice when a patient started or ended a Part A stay. The practice usually can't see that status in its own systems. It sits with the facility.

A check to run before April 2027

This is general information, not legal or compliance advice. A practice can size its exposure now instead of waiting for the adjustments:

• Pull every Medicare Part B claim line with POS 32 and a date of service from May 11, 2023 through December 31, 2024. Group the lines by facility and by patient.
• Ask each facility for those patients' Medicare Part A stay dates: admission, discharge and the date Part A coverage ended, if it did.
• Flag every line whose date of service falls inside a covered Part A stay. These are the lines the recheck is designed to find.
• Estimate the difference between the non-facility and facility amounts on the fee schedule for those codes, for that year and your locality. That's a rough size of what could be taken back.
• Ask your compliance adviser how the overpayment rules apply to anything you find. OIG asked CMS to tell practitioners to identify and return these overpayments.
• Fix the front end now: get the patient's Part A status from the facility at each visit, and use POS 31 in mixed facilities unless the physician has verified that Part A will not pay.
• From April 2027, match every Medicare adjustment against your list. Appeal only where your records show the patient wasn't in a covered Part A stay. A redetermination request must be filed within 120 days of receiving the remittance notice.

Practices that find the problem first are in a better position than practices that learn about it from their remittances.

Old claims, new money

Recoupments on old claims are easy to miss because they arrive mixed in with current payments. VOSKPO helps practices track adjustments like these back to the claims they come from. A revenue review can show where money is being taken back and why.