Comment on CMS-2026-2377-0002

The Dermatology Institute and Skin Cancer Center Comment Letter to CMS Proposed Medicare Physician Fee Schedule August 6, 2026 To the Centers for Medicare & Medicaid Services: My name is Dr. Charles Knapp, and I am co-founder of The Dermatology Institute and Skin Cancer Center, an independent dermatology practice that has served patients in Florida since 2020. I appreciate the opportunity to comment on the proposed Medicare Physician Fee Schedule and offer the perspective of an independent physician practice that has experienced firsthand the growing challenges of providing high-quality, accessible care to Medicare beneficiaries. Our practice is nestled in the center of perhaps one of the world's largest and fastest-growing retirement communities, many of whom are Medicare beneficiaries. Since we first opened our doors 6 years ago, I have witnessed a continual decline in physician reimbursement, despite the ever-increasing costs of operating my practice. Employee wages, rent, liability insurance, medical supplies, equipment, and technology costs have all increased dramatically. Administrative burden placed on physician practices today continue to worsen, with our staff spending countless hours helping patients obtain prior authorizations for life-changing biologic medications, and devoting substantial time and resources to MIPS, quality reporting, cybersecurity, compliance, electronic prescribing, and maintaining a certified electronic health record system. These responsibilities continue to expand while Medicare reimbursement has steadily declined. Dermatology routinely evaluates suspicious lesions and performs medically necessary biopsies during the same visit. This approach is efficient for patients, reduces unnecessary travel, accelerates diagnosis, and often allows earlier treatment of skin cancer. Policies that discourage comprehensive same-day care risk delaying diagnosis while increasing inconvenience and overall healthcare costs. In addition, because of the unmatched cost-effective quality of care that my practice currently provides to our patient base, many of our patients drive from hours away because they are unable to find a comparable level of care in their communities. Many of the biopsies performed in our practice are during the same visit in which a suspicious lesion is evaluated. This allows patients to receive timely diagnoses without the burden of additional travel, delayed appointments, or unnecessary follow-up visits. Policies that discourage comprehensive same-day care risk delaying diagnoses and increasing barriers for patients who already have limited access to specialty care. However, I am deeply concerned that the cumulative effect of these proposed payment reductions, combined with nearly two decades of declining physician reimbursement and rapidly increasing practice expenses, may make it extraordinarily difficult to continue operating our practice in its current form. If these proposals are finalized, independent practices like mine will likely be forced to consider difficult operational decisions simply to remain financially viable. Those decisions may include increasing the number of patients seen each day, expanding cosmetic services that are paid directly by patients, reducing staffing levels, delaying investments in personnel, or relying more heavily on technology and artificial intelligence to perform functions that are currently handled by experienced employees. These are not changes that improve patient care. Rather, they represent difficult business decisions that practices may be forced to make simply to offset continued reductions in reimbursement while the cost of providing care continues to increase. Equally concerning is the likelihood that commercial insurers will follow Medicare's lead when developing their own reimbursement policies. If these proposed payment reductions become the model for commercial payers, the financial pressures facing independent physician practices will increase even further, accelerating consolidation and reducing patient access to community-based specialty care. Ultimately, the question before CMS is not simply how physician services should be reimbursed. It is whether independent physician practices will continue to have the financial ability to provide accessible, comprehensive, community-based care for Medicare beneficiaries. My concern is not whether we are willing to continue serving these communities—it is whether the cumulative effect of continued reimbursement reductions and increasing practice costs will make it possible. I respectfully ask CMS to consider not only the financial implications of these proposals, but also the patients and communities that depend on independent physician practices every day. Thank you for your consideration. Respectfully, Charles Knapp, M.D. The Dermatology Institute and Skin Cancer Center