Comment on CMS-2026-2377-0002

Dear Administrator, I am writing to urge CMS to address the well-documented sex-based disparities in surgical reimbursement rates. Peer-reviewed research has demonstrated that identical procedures performed on female patients are reimbursed at rates up to 34% lower than the same procedures performed on male patients. Why is this still happening? Under researched, under funded and undervalued women in healthcare. It just needs to stop now. This disparity undermines the financial viability of gynecologic surgical specialization, reduces the supply of fellowship-trained surgeons, and directly contributes to higher rates of preventable complications. I respectfully request that CMS: (1) conduct a comprehensive sex-equity audit of current RVU valuations; (2) adopt objective, evidence-based methods for determining physician work values; and (3) eliminate sex-specific procedure codes where the underlying surgical work is equivalent. Kara O’Malley, Our Daughters Foundation