Comment on CMS-2026-2377-0002
Epiphany DermatologyOpposeIndividual
Summary: A medical assistant in a dermatology practice opposes the proposed Modifier 25 policy, arguing that it would disrupt efficient same-day procedures and delay diagnosis for skin cancer. The commenter emphasizes that the policy would create unnecessary inconveniences for Medicare patients and negatively impact physician workflow and patient outcomes.
I work as a medical assistant in dermatology, serving a predominantly Medicare patient population in St. Louis, Missouri. I have worked in dermatology for the past 1.5 years in a practice heavily focused on procedural care. I support patients throughout their entire visit by assisting with procedures such as biopsies and minor surgical procedures, including the excision and removal of skin cancers. I also educate patients on the importance of protecting their skin by using sunscreen daily, avoiding excessive sun exposure during high UV days, and practicing other preventive measures. Additionally, I coordinate follow-up appointments and work closely with physicians to provide the highest quality patient care.
The proposed policy will negatively affect the clinic where I work because we frequently perform same-day procedures. These procedures allow us to provide the best possible care for our patients. Many patients require biopsies during their visit so physicians can quickly and effectively diagnose and treat skin cancer. This workflow allows both our team and our patients to receive timely care. Delays in healthcare can have serious consequences and may put patients at greater risk.
Many of the Medicare patients we serve benefit from receiving the best care possible in a single visit. Requiring them to return for a procedure that could have been completed during their initial appointment creates an unnecessary inconvenience. If physicians cannot perform medically necessary procedures during the same office visit, it can lead to decreased patient satisfaction, an increase in follow-up appointments, and fewer available appointments for new patients with concerning skin conditions.
Recognizing the work of dermatology physicians and the care they provide is important because delays in care disrupt physician workflow, delay diagnosis and treatment, and ultimately affect patient outcomes. I respectfully urge CMS to reconsider the proposed Modifier 25 policy. We should preserve and recognize the value of dermatology physicians, the healthcare teams who support them, and the timely, high-quality care they provide to patients.