Comments are due Monday, September 14, 2026, at 5:00 p.m. EDT.
Dr. Mattiacci has asked us to circulate his comments and request that members and non-members alike submit an objection to CMS’s proposed Modifier 25 payment changes.
Please access the CMS comment site and lodge your objection no later than September 14. It is too late to mail comments. Submit electronically only.
Proposed Payment Changes
- Conversion factors: Proposed at $32.84 for non-qualifying APM participants (a 1.68% decrease) and $33.17 for qualifying APM participants (a 1.19% decrease).
- Overall impact: An effective aggregate decrease of roughly 2.5% when combining proposed rates with expiring temporary statutory payment authority.
- Same-day services: CMS proposes paying separately identifiable evaluation and management services on the same day as another visit or procedure at 50% of the standard amount.
How to Submit Your Comment
CMS strongly prefers electronic submissions.
- Direct comment page: https://www.regulations.gov/comment/CMS-2026-2377-0827
- Or search: Go to regulations.gov and search for CMS-1848-P or CMS-2026-2377, then click Comment.
Important: All comments must prominently reference file code CMS-1848-P so they are formally counted.
The Guild is also working to request that the AFL-CIO comment and take a position on this proposal.
Please submit your comment before the September 14 deadline.
