Comment on CMS-2026-2377-0002
Envision Eye GroupOpposeBusiness
Summary: Dr. Laiyin Ma, a solo ophthalmology specialist, opposes the proposed 50% payment reduction for E/M visits billed with modifier 25 on the same day as global procedures. The commenter argues that the proposal double-counts work, creates inefficient patient care by forcing multiple visits, and increases overall Medicare spending.
Re: File Code CMS-1848-P — Opposition to the proposed 50% payment reduction for E/M visits furnished on the same day as global procedures (Section II.D., "Accounting for E/M Resource Overlap Between Stand-Alone Visits and Global Periods")
I am a solo doctor practicing in Flushing, New York. I strongly oppose the proposal to reduce payment to 50% for a separately identifiable office/outpatient E/M visit billed with modifier 25 on the same day as a 0-, 10-, or 90-day global procedure.
Modifier 25 already requires that the visit be significant and separately identifiable — work above and beyond the evaluation built into the procedure's global package. The RUC valuation process already accounts for that overlap. This proposal discounts the same work twice.
It also creates exactly the wrong incentive. When a patient presents with a problem requiring both an exam and a same-day minor procedure — for example, punctal occlusion for dry eye disease — completing both in one visit is the efficient, patient-centered choice. Under this proposal that choice is financially penalized, and the rational response is to bring the patient back on a different day. That doubles the patient's travel, time, and cost-sharing, and it increases total Medicare spending rather than reducing it.
For supply-intensive minor procedures, an across-the-board 50% reduction also cuts reimbursement for the physical supplies bundled into the procedure's practice expense, even though those supply costs are fixed regardless of payment policy.
I am a cornea and cataract specialist and many of my patients have active corneal issues. They are elderly and requiring additional visits for simple procedures that were previously done the same day (for example, punctal plugs), would not only be a hassle, but also lead to delay in proper care and management of their disease.
CMS proposed this same policy for CY 2019 and rightly declined to finalize it after commenters raised these exact concerns. Nothing about the underlying logic has changed. I urge CMS to withdraw this proposal.
Laiyin Ma, MD
Ma Ophthalmology PLLC (DBA: Envision Eye Group)
Flushing, New York