The Honorable Mehmet C. Oz, MD, MBA
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1848-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: File Code CMS-1848-P; Medicare Program; CY 2027 Payment Policies Under the Physician Payment Schedule and Other Changes to Part B Payment and Coverage Policies; (July 16, 2026). Accounting for E/M Resource Overlap Between Stand-Alone Visits and Global Periods
Dear Administrator Oz:
On behalf of the undersigned organizations, we urge the Centers for Medicare & Medicaid Services (CMS) not to finalize the proposed policy to reduce payment by 50 percent when a separately identifiable office/outpatient (O/O) evaluation and management (E/M) service reported with modifier -25 is furnished on the same day as a procedure with a 0-, 10-, or 90-day global period. CMS advances this policy on an unsubstantiated assumption of “likely” duplication, without the evidence a change of this magnitude requires, and without addressing the concerns that led the Agency to decline a substantially similar proposal in 2019. We appreciate the Trump administration’s emphasis on keeping independent physician practices sustainable, yet we believe the unintended consequence of CMS’ proposed policy will make it extremely difficult for those practices to remain viable. We respectfully request that CMS:
- Not finalize the proposed 50 percent payment reduction for services furnished on the same date as a separately identifiable O/O E/M visit reported with modifier -25;
- Not extend the policy to procedures furnished on the same date as inpatient or other E/M services; and
- Address any genuine overlap through the established misvalued code and AMA/Specialty Society RVS Update Committee (RUC) valuation processes on a code-specific basis, rather than through a uniform, payment-level reduction, working with stakeholders where CMS believes specific codes do not fully account for overlap.
Click here to view the full AMA Federation Comments on CY 2027 Medicare Physician Fee Schedule Proposed Rule — Modifier 25 (CMS-1848-P)
