ASGE has joined national and state medical societies in urging the Centers for Medicare & Medicaid Services (CMS) to rescind a proposed policy reduce payment by 50 percent when a separately identifiable office/outpatient (O/O) evaluation and management (E/M) service reported with modifier -25 is furnished on the same day as a procedure with a 0-, 10-, or 90-day global period and would impact thousands of codes.
A letter sent to CMS on August 27 criticizes the Agency for advancing the policy on an unsubstantiated assumption of “likely” duplication, without evidence a change of this magnitude is required.
As explained in the letter, the RUC’s physician work survey instructions expressly exclude work associated with a distinct E/M service reported with modifier -25, and CMS reviews the RUC’s recommendations annually and adjusts values itself where it believes overlap has not been fully addressed. If finalized, the policy risks double-counting assumed overlaps and, consequently, undervaluing physician work.
ASGE, alongside the American College of Gastroenterology and the American Gastroenterological Association, is also preparing comments to CMS on this and other proposals contained in the CY 2027 Medicare Physician Fee Schedule Proposed Rule.