Angie Jones, a Medical Receptionist at Epiphany Dermatology, opposes the proposed CMS Modifier 25 policy. She argues that the policy fails to recognize the value of separate and identifiable professional services provided during comprehensive patient visits.

The commenter, representing clinical providers and MIPS participants, supports the proposed alternative benchmarking for topped-out measures but urges CMS to expand the scope to include Quality Measure Q130. They argue that the current 7-point cap unfairly penalizes gastroenterology practices that have limited eCQM options within their specific Value Pathways.

The commenter opposes the proposed requirement that RPM/RTM services be furnished only by clinical staff employed by the billing practice. They argue that excluding pharmacy staff will create healthcare gaps, increase hospitalization costs, and repeat past failures where office staff were unable to handle the required workload.

The owner of a behavioral health practice in Iowa opposes the proposed reduction in Medicare reimbursement for 2027. They argue that lower reimbursement rates will increase financial strain on providers, hinder recruitment of clinicians, and negatively impact access to mental health services.

The commenter, a Patient Relations Specialist, highlights the importance of CMS policies on patient care and administrative workflows. They advocate for policies that support efficient healthcare and request that CMS consider the impact of its decisions on the entire care team.

A Durable Medical Equipment (DME) supplier argues that CMS should reclassify the nebulizer compressor (HCPCS E0570) from a monthly rental to a one-time purchase. The commenter contends that the current rental model creates excessive administrative burdens, negative cash flow for suppliers, and unnecessary claims volume for Medicare.

The Ohio State University Center for Integrative Health supports the creation of a national reimbursement pathway for Shared Medical Appointments (SMAs) but opposes specific proposed restrictions on group size, session duration, and reimbursement valuation. They argue that the current proposal may undermine the financial sustainability and clinical effectiveness of these programs and request greater flexibility in program design and higher reimbursement rates.

Katie Lester, a clinic manager for a dermatology practice, opposes the proposed changes to Modifier 25. She argues that the policy change could increase administrative burdens and hinder patient access to efficient, comprehensive care by discouraging the performance of medically necessary procedures during the same visit as an evaluation.

The commenter argues that CMS should require certified EHR vendors to support all CMS-approved quality reporting methodologies as a condition of certification. They contend that providers should not be penalized for technology limitations outside their control and suggest that CMS provide technical exemptions if a vendor cannot support a required reporting method.

The commenter supports the proposed 15% increase in work RVUs for labor management and delivery codes but argues that the overall valuation of maternity care remains undervalued. They also oppose the creation of new HCPCS G-codes, citing concerns over administrative burden and reimbursement fragmentation across different payers.