Comment on CMS-2026-2377-0002

Burlington ENT PCOpposeBusiness
Summary: An ENT physician in rural Iowa opposes the proposed CMS 2027 fee schedule reduction for modifier 25. The commenter argues that the reduction will negatively impact patient care, particularly in rural areas, and may force remaining specialists to retire early.
The proposed CMS 2027 fee schedule with 50% reduction to modifier 25 will dramatically impact patient care in my rural SE Iowa ENT practice. I am the only ENT left in about a 90–100-mile radius of Burlington Iowa. I strive to provide efficient and timely care to my patients. Many of the have transportation limitations and making multiple office trips is inconvenient if not impossible. When I see a patient with a problem who needs an office EM, examination of the vocal cords for hoarseness, and then a biopsy of a lymph node to confirm cancer I try to do all of those tasks in ONE appointment. This provides the best patient care and most timely diagnosis and treatment. Under the proposed 25 modifier reduction, this would likely not happen in most practices. I use the same resources/expense/time if I do a procedure the same day as an office visit or if I have someone come back for the same procedure. Similarly, my E&M will still take the same time/resources. Neither deserves an arbitrary discounting of 50%, particularly when randomly assigned to the lesser value. This fact alone shows CMS does not care about accurate accounting or nuance. Physicians have already endured years of payment reduction relative to inflation based on the flawed "SGR" formula. Further reductions will likely prompt the few remaining Otolaryngologist practicing in rural areas to retire early. This will only exacerbate the rural health care disparity. Please do the right thing. Do not reduce 25 modifier services and provide a reasonable payment increase that is long overdue. Thank you

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