Submit Comments to CMS by September 14 on Same Day Care Policy
In the CY 2027 Medicare Physician Fee Schedule proposed rule, the Centers for Medicare & Medicaid Services (CMS) is proposing a significant payment reduction when office/outpatient E/M visits and certain procedures are provided on the same day.

If finalized, this proposal would amend CMS policy so that when a physician reports a separately identifiable office/outpatient E/M service with modifier 25 on the same day as a procedure with a 0-, 10-, or 90-day global period, only the most expensive service would be paid at 100 percent. Every other service or procedure that day would be cut by 50 percent.

To support member participation, AAPM&R has developed a template comment letter to help members get started. Please note, comments are limited to 5000 characters. While the template provides key messages and concerns, personalized comments are required for CMS to count your letter as an individual response and for them to understand the real-world implications of this proposal. Physicians are encouraged to customize the letter by describing their practice setting, patient population, and clinical experiences. 

For additional information on this issue, other key priorities in the fee schedule you may want to comment on, and suggestions for customizing your email including an AI prompt, See our FAQ.

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