APMA is profoundly disappointed by the decision by CMS to move forward with a 20% reduction in payment for certain services reported on the same day with Modifier 25. The arbitrary cut, included in the Medicare Physician Fee Schedule final rule, will harm physician practices and restrict patient access to needed care.
Thanks to APMA’s tireless advocacy, CMS mitigated its original proposal of a 50% cut. Any cut, however, will have a detrimental impact on physicians and patients nationwide.
“CMS chose to move forward despite clear and consistent warnings from physicians across specialties and their patients,” said APMA President Patrick DeHeer, DPM. “This policy will threaten access to care, particularly for underserved and rural populations, and it will undermine the ability to provide medically necessary same-day care. APMA unequivocally condemns any move to limit or delay patient access to needed health care.”
APMA has advocated against this proposal through its own channels and as part of the Same Day Care Coalition. More than 6,000 patients, podiatrists, and students joined the effort through APMA’s eAdvocacy campaign.
Urge Congress to halt implementation by writing to your legislators through APMA’s eAdvocacy site: https://apma.org/eAdvocacy
Specifically, CMS finalized a 20% reduction in payment when an office/outpatient evaluation and management visit is billed with Modifier 25 alongside a 0-day global procedure. The highest-paid service remains fully paid, while other applicable services receive the reduction. The policy applies to services furnished by the same physician or physicians of the same specialty in the same group practice.
The final rule also includes:
- Overall impact on podiatry: For most podiatrists, the CY 2027 conversion factor will be $32.6286, down 2.31% from 2026. Based on practice mix and statutory payment changes, APMA estimates an overall decrease of approximately 3.2% for podiatrists. Impacts will vary by practice.
- Skin substitutes: CMS finalized national pricing for non-sheet products at $127.14 per square centimeter of wound surface area treated, consistent with sheet-form products.
- MIPS/MVPs: Traditional MIPS remains available through the 2030 performance year, with mandatory MVP reporting beginning in 2031 for eligible clinicians not reporting through the APM Performance Pathway. CMS also finalized a Diabetic Disease MVP and Podiatry MVP updates.
- Global surgical services: CMS paused required postoperative visit reporting using CPT code 99024.
- G2211: Modifier B1 will replace G2211, increasing eligible E/M services’ total relative value units by 16%. B2 provides a 32% increase in total RVUs for qualifying ACO services. Existing Modifier 25 restrictions remain.
APMA will continue to analyze the final rule and share more information in the coming days.
