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CMS Proposes 2027 Payment Cuts to Modifier 25
Idaho Physicians: Your Voice Matters!
What is Modifier 25 used for?
Modifier 25 lets a physician bill a significant, separately identifiable E/M visit on the same day as a procedure. These aren't duplicate services as they represent real, distinct work. The result of using this modifier pays separately for the E/M service and other procedures or services that are performed during the same visit.
What CMS is proposing
CMS's 2027 Medicare Physician Fee Schedule proposed rule would cut payment when a same-day office/outpatient E/M visit (billed with modifier 25) is furnished by the same physician, or another physician in the same group, alongside a 0- or 10-day global procedure. Under the proposal, Medicare would pay the more expensive service (surgical or E/M) at 100% and the other at just 50%. CMS is also asking whether the policy should extend to other E/M visits, including inpatient care.
Why it matters
Idaho physicians routinely diagnose and treat patients in a single visit – examples include skin biopsies, joint injections, abscess drainage, cryotherapy, ingrown toenail removal, laceration repair, trigger point injections, and earwax removal. Cutting payment for these same-day services creates pressure to split them into two appointments instead of one.
Potential impact on patients
- More appointments and longer wait times
- Extra travel and time away from work
- Higher out-of-pocket costs
- Delayed treatment and missed follow-up care
Potential impact on practices
- Pressure to schedule visits and procedures separately
- Lower reimbursement for efficient, medically-necessary care
- More administrative burden trickling down to billing
- Added financial strain, especially for smaller practices
Specialties expected to be hit hardest
CMS identifies otolaryngology, dermatology, hand surgery, and colon/rectal surgery as most likely to be affected by the modifier 25 change specifically, yet, we believe primary care would also be hard hit. When combined with other proposed cuts (including removal of the Indirect Practice Cost Index and previously finalized code-level reductions), dermatology, otolaryngology, orthopedic surgery, and hand surgery and to a lesser degree ophthalmology, neurosurgery, and plastic surgery could also see significant overall decreases.
Why this concerns us
The AMA 's RUC already builds overlap between E/M services and same-day procedures into how CPT codes are valued. This cut would duplicate an adjustment that's already been made. CMS itself acknowledges physicians shouldn't schedule services just to maximize payment, but the proposal creates exactly that incentive, while also raising the specter of audits for physicians making good-faith scheduling decisions. And CMS's own reference to 90-day global periods is puzzling, since modifier 25 isn't used with 90-day global surgeries in the first place (that would be modifier 57).
What you can do
We are asking all IMA members (providers, office staff, administration) to individually submit a comment to CMS referencing file code CMS-1848-P. The deadline is September 14, 2026. A short, personal example of how this rule would affect your patients or practice carries real weight as every comment is reviewed. We've created a template to copy and revise to share how this will impact your practice.
The Idaho Medical Association is reviewing the full proposed rule and preparing formal comments to CMS. We will keep members updated as this develops.
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