Comment on CMS-2026-2377-0002

Re: File Code CMS-1848-P — Opposition to the proposed 50% payment reduction for E/M visits furnished on the same day as global procedures (Section II.D., "Accounting for E/M Resource Overlap Between Stand-Alone Visits and Global Periods") I am a solo doctor practicing in Burbank, CA. I strongly oppose the proposal to reduce payment to 50% for a separately identifiable office/outpatient E/M visit billed with modifier 25 on the same day as a 0-, 10-, or 90-day global procedure. Modifier 25 already requires that the visit be significant and separately identifiable — work above and beyond the evaluation built into the procedure's global package. The RUC valuation process already accounts for that overlap. This proposal discounts the same work twice. It also creates exactly the wrong incentive. When a patient presents with a problem requiring both an exam and a same-day minor procedure — for example, punctal occlusion for dry eye disease — completing both in one visit is the efficient, patient-centered choice. Under this proposal that choice is financially penalized, and the rational response is to bring the patient back on a different day. That doubles the patient's travel, time, and cost-sharing, and it increases total Medicare spending rather than reducing it. For supply-intensive minor procedures, an across-the-board 50% reduction also cuts reimbursement for the physical supplies bundled into the procedure's practice expense, even though those supply costs are fixed regardless of payment policy. My practice is heavy with dry eye patients, it is an established practice for 16 years. CMS proposed this same policy for CY 2019 and rightly declined to finalize it after commenters raised these exact concerns. Nothing about the underlying logic has changed. I urge CMS to withdraw this proposal. Suhas Tuli, MD Tuli Eye Care Center 2601 West Alameda Avenue, Suite 206, Burbank CA 91505