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The Urgent Care Association (UCA) continues to seek differentiation for urgent care in the place of service (POS) definitions used by the Centers for Medicare and Medicaid Services (CMS) to construct payment schedules, which are updated yearly. In the 2026 Medicare Physician Fee Schedule, UCA’s advocacy efforts were noted in the Federal Register document with a statement indicating comments offered about the POS for urgent care will be taken into consideration by CMS for possible future rulemaking. On pages 81-83, the document reads in part: “POS 20 refers to Urgent Care Facilities but does not adequately differentiate between those that offer services more akin to the typical general practitioner’s office and those that offer enhanced diagnostic and therapeutic services and extended hours. They [commenters] recommended that the creation of a new POS code describing ‘enhanced’ urgent care centers that offer specific diagnostic and therapeutic services and that operate outside typical business hours could fill this need.”

You are seen and heard: Although no change was made for 2026, UCA notes that the POS question is on the radar for CMS, which is an encouraging signal of progress.

CMS May Refine Place of Service Code For Urgent Care
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