After two years of uncertainty, nursing home providers may soon get clarity on proposed changes to Medicare’s non-therapy ancillary (NTA) payment system — a move that could significantly affect reimbursement for facilities caring for medically complex residents.
The NTA system is part of the Patient Driven Payment Model (PDPM), which replaced the RUG-IV payment structure in 2019. Under PDPM, NTA codes provide additional reimbursement for residents with costly conditions such as HIV/AIDS, ventilator dependency, chronic obstructive pulmonary disease (COPD), and certain wound infections.
Federal regulators first proposed revising the NTA point system in the fiscal year (FY) 2025 Medicare payment rule and again in the FY 2026 proposal. However, both times the agency held off on finalizing the changes after providers raised concerns about potential reimbursement cuts.
Industry experts say the issue could resurface during upcoming Medicare rulemaking for skilled nursing facilities.
“I was honestly surprised the revised NTA points were not addressed in the FY 2026 final rule,” said Jennifer Napier, practice director at Engage Consulting. “I’d be even more surprised if they aren’t included in the 2027 rulemaking.”
Because the revisions have already been discussed in prior rulemaking proposals, regulators could revisit the changes in a future final rule.
Cuts Raise Concerns
Several proposed changes have alarmed providers. Facilities caring for residents with HIV/AIDS could see NTA points fall from eight to seven. Ventilator-dependent patients — among the most resource-intensive cases — could drop from four points to just one.
“That is scary because those are really acute-care providing facilities,” Napier said, pointing to the high cost associated with caring for ventilator-dependent residents.
The proposal would also eliminate NTA codes for malnutrition and multiple sclerosis, reduce points tied to COPD, and cut payments for wound infections.
Some experts say those reductions do not align with rising care costs. “Costs have been increasing, so the point structure should not be reduced,” said Maureen McCarthy, president and CEO of Celtic Consulting and a former CMS payment specialist.
Behavioral Health Additions
At the same time, the proposal introduces new NTA points for conditions including anxiety, bipolar disorder, and post-traumatic stress disorder — diagnoses that are becoming increasingly common among nursing home residents.
Additional points would also apply to certain cardiac conditions, prosthetic devices, and rare cases involving lung transplant patients.
Because each NTA point translates directly into daily reimbursement, even small changes can have significant financial implications for providers. Industry observers say the pending rule could reshape how facilities are paid for treating some of their most complex patients.
