MedicaidAdministrativeMedium impact
Independent Nurse Bulletin 23: Third-Party Liability Requirements for Independent Nurse Providers
MassHealth·MA·Provider Bulletin
Effective date
Mar 1, 2026
We identified it
Jun 18, 2026
Summary
Independent nurses providing continuous skilled nursing (CSN) services to MassHealth members must exhaust all commercial insurance options before billing MassHealth, including obtaining new coverage determinations for qualifying events like new admissions or changes in medical condition. Providers must maintain detailed documentation of all efforts to obtain payment from commercial insurers for a minimum of six years.
Action Required
Immediately: Independent nurse providers must establish workflows to seek commercial insurance payment before billing MassHealth for CSN services. Document all correspondence with commercial insurers including EOBs, coverage determinations, and contract enrollment attempts. Create separate files for commercial insurer documentation and retain for minimum six years. Obtain new coverage determinations from commercial insurers for any qualifying events including new admissions, changes in medical condition, or insurance status changes. Failure to comply may result in sanctions and overpayment liability.