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Help Stop Medicare Cuts to Same-Day ENT Care

CMS's 2027 Proposed Fee Schedule Threatens Same-Day, Multi-Service Care

Medicare patients often present with more than one health concern.

In many cases, the most efficient approach is to evaluate those concerns, perform any necessary procedures, and coordinate treatment in a single visit.

CMS's proposed 2027 Medicare Physician Fee Schedule could undermine that model. The policy would pay 100% for the highest-valued service, then cut payment by 50% for additional services performed during the same encounter.

Specifically, the proposal would reduce payment for the lower-valued service(s) when a separately identifiable office/outpatient evaluation and management (E/M) service is billed with Modifier 25 on the same day as a 0-, 10-, or 90-day global surgical procedure.

Medicare's existing payment methodology already accounts for shared practice expenses—staff time, exam-room use, and administrative support—built into the relative value units for each service. What the proposal fails to account for is the distinct, medically necessary work that remains: evaluating a second condition, counseling a patient, performing a procedure, or coordinating care. That work does not become less resource-intensive simply because it occurs on the same day as another service.

Why This Policy Is Flawed

Complete care is not duplicate care.

This policy would apply when these services are provided by the same physician or another physician within the same group practice. Medicare should support complete care in one visit—not penalize it. 
Practice Impact

This proposal adds direct financial pressure on independent and small-group practices, and it could accelerate consolidation industry-wide. It also runs counter to the administration's stated priorities: preserving physician autonomy, reducing administrative burden, and supporting independent practice viability.

Specialty-specific Impact

CMS estimates that Medicare payments for office-based otolaryngology will decrease by 10% in 2027, largely due to this proposed policy. ENTs would be disproportionately affected because they often provide seniors with several medically necessary services in a single visit, such as E/M, cerumen removal, and laryngoscopy. Each requires separate clinical judgment, physician time, and coordination.

Modifier 25 Physician Resources