Comment on CMS-2026-2377-0002

Dear CMS, I am writing to express my concern regarding the proposed 2027 Medicare Physician Fee Schedule changes affecting reimbursement for services billed with Modifier 25. In dermatology, it is very common for a patient to come in for an evaluation and, during that same visit, need a medically necessary procedure such as a biopsy. These are two separate services. The evaluation requires its own medical decision making, examination, documentation, and treatment planning. The procedure requires additional clinical judgment, consent, supplies, specimen handling, documentation, patient education, wound care instructions, and follow-up. Performing both services during the same appointment benefits the patient. It can prevent delays in diagnosis, reduce the need for additional appointments, decrease time away from work or family responsibilities, and allow concerning lesions to be addressed promptly. Providing these services efficiently during one visit does not make either service less valuable or less medically necessary. I am concerned that reducing reimbursement when a separately identifiable E/M service and a procedure occur on the same day could unintentionally discourage practices from providing both services during one visit. This could result in patients having to return for another appointment simply to receive care that could have safely and appropriately been provided at the initial visit. The impact could be especially significant for patients who already face barriers to care, including long travel distances, limited appointment availability, transportation difficulties, work obligations, and financial concerns. Modifier 25 exists to identify situations in which a significant, separately identifiable E/M service is performed in addition to another service or procedure. When the documentation supports both services, physicians and advanced practice providers should continue to receive appropriate reimbursement for the work performed. I respectfully ask CMS to reconsider this proposed change and preserve appropriate reimbursement for separately identifiable professional services provided during the same patient encounter. Protecting this distinction supports timely diagnosis, efficient care, patient access, and the ability of dermatology practices to continue providing comprehensive care. Thank you for considering my comments.