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.
Complete care is not duplicate care.
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.