The commenter, an independent Registered Dietitian Nutritionist, opposes the proposal to bundle Medical Nutrition Therapy (MNT) payments into Shared Medical Appointments (SMAs). They argue that this could make nutrition services financially invisible and reduce access to specialized care, requesting that MNT remain separately reimbursable.

The commenter, a Registered Nurse and Clinic Supervisor at a dermatology practice, opposes the proposed Modifier 25 policy. They argue that the policy would reduce reimbursement for separate and identifiable professional services, potentially leading to staffing shortages, longer wait times, and decreased access to care for patients.

A practicing clinician opposes the proposed CMS payment policies for remote care, arguing that the employed-staff-only restriction, initiating visit requirement, and flat G-code consolidation would end essential services for rural and underserved patients. The commenter advocates for the OIG's 2024 recommendations, which focus on oversight and credentialing rather than restrictions that eliminate clinical partnerships.

Dr. Suhas Tuli, owner of Tuli Eye Care Center, opposes the proposed 50% payment reduction for E/M visits billed with modifier 25 on the same day as global procedures. He argues that the proposal double-counts overlap, creates inefficient patient care by penalizing same-day procedures, and fails to account for fixed supply costs.

The commenter expresses concern that the proposed CMS-1848-P will lead to reimbursement reductions and increased administrative burdens for specialty providers like podiatry practices and ambulatory surgery centers. They argue these changes threaten the financial viability of independent facilities and could ultimately limit patient access to cost-effective care.

A medical practice provider opposes the proposed rule (CMS-1848-P), arguing that the reimbursement cuts will threaten the financial sustainability of medical practices and negatively impact access to care for rural patients. The commenter highlights that these cuts will force patients to travel long distances for procedures, creating significant logistical and financial burdens for them.

Koskie Gibson, Clinical Director of Drayer PT, opposes the proposed changes to Remote Therapeutic Monitoring (RTM) reimbursement and staffing requirements. The commenter argues that requiring RTM clinical staff to be directly employed by the billing practice could make programs financially unsustainable and reduce patient access to necessary clinical support.

John Vanschagen, representing Trinity Health West Michigan, supports the expansion of the Primary Care Exception to include all office and outpatient E/M services (including 99214 and 99215). He argues that the proposal reflects the clinical complexity of patients seen in residency continuity clinics and supports the educational principle of graduated autonomy for residents.