Comment on CMS-2026-2377-0002
Epiphany DermatologyOpposeBusiness
Summary: Jessica J Solberg, a medical assistant at Epiphany Dermatology, opposes the proposed Medicare Physician Fee Schedule policy that would reduce payments for separately identifiable evaluation and management services performed on the same day as a medically necessary procedure. She argues that the reduction would create barriers to timely care, increase administrative burdens, and negatively impact patient access and outcomes.
I am a medical assistant in a dermatology practice in Georgia, and I am writing to oppose the proposed CY 2027 Medicare Physician Fee Schedule policy that would reduce payment when a physician or advanced practice provider performs a separately identifiable evaluation and management service and a medically necessary procedure during the same visit.
As a medical assistant, I help prepare patients for biopsies, cryotherapy, and other procedures, educate patients about what to expect, assist during procedures, and coordinate follow-up care. I see every day how valuable it is when patients can be evaluated and treated during a single appointment whenever it is medically appropriate.
I respectfully ask CMS to:
Withdraw the proposed 50% reduction for separately identifiable evaluation and management services and same-day medically necessary procedures.
Preserve policies that allow clinicians to evaluate patients and provide medically necessary treatment during the same visit when appropriate.
Continue working toward sustainable physician reimbursement that reflects the increasing cost of providing care.
Consider how repeated reimbursement reductions affect staffing, patient access, and the ability of practices to provide timely care.
Carefully evaluate the effects this proposal would have on patient costs, treatment delays, loss to follow-up, and specialty access before implementing it.
Many patients are relieved when they learn that a biopsy or cryotherapy can be performed during the same visit instead of requiring another appointment. When patients are asked to come back on another day, they often express concerns about another copayment, missing more work, transportation, childcare, or taking additional time away from family responsibilities. Some patients cancel or never return.
When a suspicious skin lesion is found, performing a biopsy immediately allows the diagnostic process to begin without delay. Melanoma, Merkel cell carcinoma, and high-risk squamous cell carcinoma can all become life-threatening if diagnosis is postponed. Likewise, treating actinic keratoses with cryotherapy during the same visit can help prevent progression to squamous cell carcinoma.
This proposal also concerns me because it may make scheduling and coordinating patient care more difficult. Additional appointments create more work for office staff while increasing wait times for other patients who need appointments. It also places additional strain on practices that are already working hard to provide timely access to care.
Medical assistants are an important part of the healthcare team, and we want to help patients receive the care they need as efficiently as possible. Healthcare policy should support timely, patient-centered care rather than create unnecessary barriers that make care more complicated for patients and medical practices alike.
Thank you for considering my comments.
Sincerely,
Jessica J Solberg
Medical Assistant ll
Epiphany Dermatology
Georgia