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.

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 medical practice provider opposes the proposed rule (CMS-1848-P), arguing that the reimbursement cuts will threaten the financial sustainability of medical practices and negatively impact access to care for rural patients. The commenter highlights that these cuts will force patients to travel long distances for procedures, creating significant logistical and financial burdens for them.

Koskie Gibson, Clinical Director of Drayer PT, opposes the proposed changes to Remote Therapeutic Monitoring (RTM) reimbursement and staffing requirements. The commenter argues that requiring RTM clinical staff to be directly employed by the billing practice could make programs financially unsustainable and reduce patient access to necessary clinical support.

John Vanschagen, representing Trinity Health West Michigan, supports the expansion of the Primary Care Exception to include all office and outpatient E/M services (including 99214 and 99215). He argues that the proposal reflects the clinical complexity of patients seen in residency continuity clinics and supports the educational principle of graduated autonomy for residents.

The commenter, likely an independent medical practitioner, opposes the reduction of the conversion factor. They argue that rising overhead costs for private practices are forcing providers to join large corporations, which they claim will increase costs for Medicare and Medicaid patients.

Birmingham Obstetrics & Gynecology, P.C. supports the adoption of new maternity care CPT codes for 2027 and opposes the creation of HCPCS G-codes that would preserve the old global billing structure. They argue that maintaining parallel coding systems would increase administrative burdens, cause confusion, and fail to accurately reflect contemporary individualized prenatal care.

JoAnn Reis, CEO of a privately owned orthopaedic practice, opposes proposed Medicare reimbursement reductions for hip, shoulder, and knee arthroplasty. She argues that these cuts, along with changes to the physician fee schedule and conversion factor, threaten the financial sustainability of independent practices and will reduce patient access to timely, high-quality surgical care.

FirstVitals Inc. opposes the proposed "employed-staff-only" requirement for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM), arguing that it unnecessarily restricts referral-based models. The company proposes a "Qualified Practice-Integrated Remote Care Organization" (QPIRCO) framework that allows Medicare-enrolled practices to use qualified contracted personnel while maintaining clinical oversight and billing integrity.