What Are the Proposed Medicare Billing Codes for Urgent Care?
As of August 2026, CMS has not yet proposed specific billing code numbers for urgent care visits, but the agency has spent three consecutive rulemaking cycles asking whether separate coding and payment is needed for evaluation and management services delivered at urgent care centers. In the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), published July 14, 2026, CMS continued this discussion alongside a bipartisan congressional push for dedicated urgent care reimbursement. The public comment period closes September 14, 2026.
Three-year buildup: CMS first raised the question in the CY 2025 PFS, asked more specifically in the CY 2026 PFS, and Congress formally urged action in a March 2026 letter to CMS.
What it could change: Dedicated codes would give urgent care centers a distinct reimbursement pathway rather than sharing the same E/M code set designed for physician offices and emergency departments.
What to do now: Urgent care operators can submit public comments to CMS at regulations.gov before September 14, 2026, referencing file code CMS-1848-P.
What CMS Has Proposed So Far
The path toward separate urgent care billing codes has unfolded across three PFS rulemaking cycles, each one more specific than the last.
In the CY 2025 Physician Fee Schedule, CMS included a comment solicitation asking stakeholders how urgent care centers can play a role in addressing emergency department capacity issues. The language was broad and exploratory, focused on system-level problems rather than payment mechanics.
CMS narrowed the focus in the CY 2026 PFS by directly asking whether separate coding and payment is needed for evaluation and management visits furnished at urgent care centers. This was the first time CMS framed the question as a potential billing and payment change rather than a general healthcare delivery discussion.
On March 6, 2026, a bipartisan group of House members sent a formal letter to CMS Administrator Dr. Mehmet Oz urging the agency to move past stakeholder input and into actual policy proposals. The letter cited MedPAC findings that roughly one-third of nonurgent emergency department claims, approximately 500,000, could be treated appropriately in urgent care centers at about one-third of the cost. The letter also referenced CMS data showing that median ED wait times increased from 2 hours and 18 minutes in 2014 to 2 hours and 40 minutes in 2022.
The CY 2027 PFS proposed rule, published July 14, 2026, continues the discussion. CMS is accepting public comments through September 14, 2026, and the final rule is expected in November 2026. In our experience matching providers with billing partners, three consecutive years of CMS attention on a single payment question is unusual, and it signals that some form of policy action is being actively considered.
Who Would Separate Urgent Care Codes Affect?
The most immediate impact would fall on the more than 9,000 urgent care centers operating across the United States. Any facility that bills Medicare E/M codes under place of service 20 would be directly affected by new coding requirements.
Practice managers and billing staff would need to update charge capture templates, EHR superbills, and clearinghouse configurations to accommodate new code sets. Billing companies that specialize in urgent care would also need to reprogram their systems and retrain staff on the new codes.
The downstream effect extends to patients. Separate urgent care codes could shift how Medicare calculates cost-sharing for urgent care visits, potentially changing copay amounts. Providers often come to us after a major billing rule change creates confusion, and a new code set would be one of the larger workflow changes the urgent care industry has seen since CMS established place of service code 20.
The proposal would not affect ED billing. Emergency department E/M codes (99281 through 99285) are a separate code family. Separate urgent care codes would create a parallel track, not replace existing ED billing. If your facility handles both urgent care visits and higher-acuity cases that use ED-level E/M codes like CPT 99281, the distinction between the two workflows would become even more important to document correctly.
Why CMS Is Considering the Change
The core argument is cost efficiency. Emergency departments are expensive. CMS data shows the median ED visit costs Medicare significantly more than the same visit handled in an urgent care setting, largely because of the facility fees, staffing ratios, and overhead built into the hospital outpatient prospective payment system.
The bipartisan congressional letter put specific numbers on the problem. According to MedPAC, roughly 500,000 nonurgent ED claims per year could be treated at an urgent care center at approximately one-third of the cost. ED overcrowding contributes to staff burnout, medical errors, and longer wait times. The argument to Congress and CMS is straightforward: if you pay urgent care centers appropriately, more patients will be routed there instead of the ED, and the system saves money.
From a coding perspective, urgent care visits currently use the same office/outpatient E/M code set (99202 through 99215) as primary care offices. Some payers also require the flat-rate urgent care S-code (S9083 or S9088) instead of, or in addition to, E/M codes. This inconsistency creates a payer-by-payer billing grid that is one of the most common pain points we hear from urgent care operators seeking billing help. Dedicated codes could standardize how every payer recognizes and reimburses an urgent care visit.
There is also a data gap. Without distinct codes, CMS cannot accurately track urgent care utilization, visit acuity, or outcomes in Medicare claims data. Separate codes would give the agency granular data to evaluate whether shifting low-acuity patients from the ED to urgent care is actually reducing costs and improving outcomes.
How Would Separate Codes Change Urgent Care Billing?
Current E/M and S-Code Workflow
Today, urgent care centers bill Medicare using the standard office/outpatient E/M codes (99202 through 99215), selected based on medical decision-making complexity or total time. Place of service code 20 identifies the claim as an urgent care visit. Some commercial payers require the S9083 flat-rate code instead.
This creates three problems. First, the E/M codes do not reflect the walk-in, episodic, high-throughput nature of urgent care. Second, the S-code is not recognized by Medicare at all. Third, every billing company handling urgent care claims maintains a payer-specific grid dictating which code set to use for each carrier. Across the billing companies we vet, maintaining and updating that grid is consistently cited as one of the highest-effort, highest-error tasks in urgent care revenue cycle management.
What Dedicated Urgent Care Codes Could Look Like
CMS has not published draft code numbers, but based on the trajectory of the RFIs and the congressional letter, the most likely structure would be a dedicated E/M code family specific to urgent care, similar to how emergency departments have their own code series (99281 through 99285). An alternative approach CMS has also floated is an add-on payment to existing E/M codes when billed with POS 20.
| Billing Element | Current System | With Separate UC Codes |
| Code set | 99202-99215 (shared with offices) | Dedicated UC E/M family or add-on modifier |
| Medicare recognition | Recognized via POS 20 only | Distinct code identifies UC visit in claims data |
| Payer grid complexity | E/M vs. S9083 varies by carrier | Standardized code set across payers |
| CMS data visibility | UC visits blended with office visits | Granular UC utilization tracking |
| Reimbursement rate | Office-based E/M rate with POS 20 | Potentially UC-specific rate reflecting walk-in model |
Whether the final structure is a new code family or an add-on modifier, the operational result would be the same: urgent care visits would have a distinct billing identity in the Medicare system for the first time.
What to Do Before the September 14 Deadline
The CMS comment period on the CY 2027 PFS proposed rule closes September 14, 2026. Urgent care operators, billing companies, and industry associations can submit comments at regulations.gov under file code CMS-1848-P. Here is how to prepare.
1. Review your current modifier 25 exposure. The same proposed rule includes a 50% payment reduction on same-day E/M visits billed alongside procedures with global periods. If your clinic performs laceration repairs, splinting, or injections alongside office visits, model the revenue impact now. For a detailed breakdown of that provision, see our guide to the proposed modifier 25 payment cut for urgent care.
2. Pull your POS 20 claim volume for the last 12 months. Quantifying how many Medicare visits your facility bills under POS 20 gives you a data point to include in a public comment. CMS responds to volume-backed arguments more than general statements.
3. Document the payer grid problem. If your billing team maintains a carrier-by-carrier matrix dictating E/M versus S-code billing, that complexity is exactly what CMS is trying to solve. Include that operational burden in your comment.
4. Calculate the cost differential. If you can demonstrate what your average urgent care visit costs versus the average ED visit for the same acuity level, that data directly supports the case for separate urgent care payment.
5. Submit the comment before September 14, 2026. Go to regulations.gov, search for CMS-1848-P, and submit your comment electronically. Comments submitted after the deadline may not be considered in the final rule.
6. Flag the issue to your billing partner. If you work with an outsourced billing company, make sure they are tracking this development. A new code set would require system updates on their end, and early awareness means a smoother transition if the policy is finalized.
If this proposal moves forward, having a billing partner who already understands urgent care coding will matter more than ever. Get matched with urgent care billing companies who track Medicare policy changes and can adjust your revenue cycle before new rules take effect.
Common Misunderstandings About This Proposal
One question we hear constantly from practice managers is whether this means urgent care will get its own fee schedule. It does not, at least not based on what CMS has discussed so far. The most likely outcome is a new code family or modifier within the existing Medicare Physician Fee Schedule, not an entirely separate payment system.
Another misconception is that this is already finalized. It is not. CMS has been gathering information, not writing rules. The earliest any new urgent care codes could take effect would be CY 2028, assuming CMS proposes specific codes in the CY 2028 PFS rulemaking cycle. The CY 2027 proposed rule does not contain draft code numbers or specific payment rates for urgent care.
Some providers assume this only matters for Medicare patients. In practice, when Medicare creates a new code set, commercial payers and Medicaid programs tend to adopt it within 12 to 24 months. The billing companies we connect providers with consistently report that a Medicare coding change becomes a commercial payer requirement faster than most practices expect.
Finally, there is a concern that separate codes would reduce payment by classifying urgent care visits at a lower acuity than the office E/M codes currently allow. The congressional letter specifically argued for payment that reflects the true cost of urgent care delivery, not a downgrade. The intent, based on every public document CMS has released, is to create an accurate payment pathway, not a cheaper one.
Frequently Asked Questions
No. As of August 2026, CMS has only solicited stakeholder input on whether separate coding and payment is needed. No draft code numbers, code descriptors, or payment rates have been proposed. The earliest specific codes could appear is the CY 2028 PFS proposed rule, likely published in mid-2027.
CMS has not addressed S9083 directly in the RFIs. S9083 is a HCPCS S-code used by some commercial and Medicaid payers, not Medicare. If CMS creates dedicated urgent care codes for Medicare, commercial payers may adopt them over time, which could eventually simplify or replace the S-code workflow for those carriers.
Go to regulations.gov, search for file code CMS-1848-P, and submit your comment electronically before September 14, 2026. Include specific data points from your practice, such as POS 20 claim volume, payer grid complexity, and cost comparisons to ED visits for similar acuity levels.
Ambulance billing uses its own code set (A0427 through A0434) and is not affected by E/M code changes. If your facility receives patients via ambulance transport coded under A0427, that billing pathway would remain separate from any new urgent care E/M codes.
They are independent provisions. The modifier 25 same-day payment reduction applies to the existing E/M code set and would take effect January 1, 2027, if finalized. Separate urgent care codes are still in the discussion phase and would not arrive before 2028 at the earliest. Both deserve attention, but they run on different timelines.
The intent expressed by CMS and Congress is to create a payment pathway that accurately reflects urgent care delivery costs. Whether rates end up higher or lower than current E/M rates depends on how CMS values the new codes. The strongest way to influence that outcome is to submit a comment with real cost data from your facility before the September 14 deadline.
Next Steps
Review the full breakdown of the proposed modifier 25 payment cut that is also included in the CY 2027 rule.
Pull your POS 20 claim data and submit a comment to CMS at regulations.gov (file code CMS-1848-P) before September 14, 2026.
If you are evaluating billing partners ahead of potential code changes, request a free quote to compare urgent care billing companies matched to your facility size and volume.
Medicare billing rules for urgent care are changing. Whether it is the proposed modifier 25 reduction, the conversion factor cut, or the potential for entirely new billing codes, having a billing partner who specializes in urgent care keeps your revenue cycle ahead of the curve.
