Comment on CMS-2026-2377-0002

I am a Registered Nurse and Clinic Supervisor at a dermatology practice serving patients throughout northern New Jersey. In my role, I work closely with physicians, advanced practice providers, clinical staff, and patients every day to ensure that high-quality dermatologic care is delivered efficiently, safely, and compassionately. I see firsthand the value of providing comprehensive evaluation and management (E/M) services alongside medically necessary procedures, such as skin biopsies, during the same patient visit. These are separate and identifiable professional services that require independent clinical judgment, patient assessment, informed consent, documentation, specimen handling, patient education, wound care instructions, care coordination, and follow-up planning. Delivering both services during one appointment improves patient care and convenience—it does not make either service less valuable or require less work from the healthcare team. Many of our patients are Medicare beneficiaries who have multiple skin concerns that deserve prompt evaluation. Combining an office visit with a medically necessary procedure allows us to diagnose potential skin cancers and other serious conditions without unnecessary delays. It also reduces the burden of additional appointments, transportation challenges, time away from work or family, and unnecessary healthcare costs for our patients. As a clinic supervisor, I am also concerned about the operational impact of the proposed Modifier 25 policy. Reduced reimbursement for separate and identifiable professional services could make it more difficult for practices to maintain staffing, invest in resources, and continue providing timely access to care. Dermatology already faces workforce shortages, and policies that discourage efficient, comprehensive care could ultimately result in longer wait times and decreased access for patients who need us most. I am also concerned that commercial insurers may adopt similar payment policies if this proposal is finalized, extending these negative effects beyond Medicare patients and impacting access to dermatologic care across all patient populations. Modifier 25 has long recognized that evaluation and management services and medically necessary procedures performed during the same encounter are distinct professional services. That recognition reflects the expertise, time, resources, and coordination required to provide comprehensive, patient-centered care. I respectfully urge CMS to reconsider the proposed Modifier 25 policy and preserve reimbursement policies that appropriately recognize separate and identifiable professional services. Maintaining these policies will help protect patient access to timely, high-quality dermatologic care, support healthcare teams, and ensure the continued sustainability of practices that serve communities like those throughout northern New Jersey.