Dr. Suhas Tuli, owner of Tuli Eye Care Center, opposes the proposed 50% payment reduction for E/M visits billed with modifier 25 on the same day as global procedures. He argues that the proposal double-counts overlap, creates inefficient patient care by penalizing same-day procedures, and fails to account for fixed supply costs.

A practicing clinician and owner of a practice that partners with a clinical monitoring organization opposes the proposed CMS payment policies. The commenter argues that the proposed employment restrictions, initiating visit requirements, and flat-rate payment consolidations would end remote monitoring services for their patients, particularly in rural and underserved areas.

A healthcare provider at a skilled nursing facility opposes proposed reimbursement reductions for CPT code 97610 in the CY 2027 Medicare Physician Fee Schedule. The commenter argues that the proposed cuts are based on inaccurate cost estimates and would make the woundmist technology financially unsustainable for treating severe, chronic wounds.

The commenter argues that CMS should require certified EHR vendors to support all CMS-approved quality reporting methodologies as a condition of certification. They contend that providers should not be penalized for technology limitations outside their control and suggest that CMS provide technical exemptions if a vendor cannot support a required reporting method.

The commenter supports the proposed 15% increase in work RVUs for labor management and delivery codes but argues that the overall valuation of maternity care remains undervalued. They also oppose the creation of new HCPCS G-codes, citing concerns over administrative burden and reimbursement fragmentation across different payers.

The commenter expresses concern that the proposed CMS-1848-P will lead to reimbursement reductions and increased administrative burdens for specialty providers like podiatry practices and ambulatory surgery centers. They argue these changes threaten the financial viability of independent facilities and could ultimately limit patient access to cost-effective care.

A practicing clinician opposes the proposed CMS payment policies for remote patient monitoring, arguing that the employment restrictions and payment consolidations would end the service for rural and underserved patients. The commenter advocates for the OIG's recommendations, which focus on oversight and credentialing rather than restricting clinical staffing models.