Downcoded

The Cut Got Smaller and Found 149,000 More Doctors

CMS finalized the modifier 25 reduction at 20 percent instead of 50, and only against 0-day globals. The second public use file shipped with the CY2027 fee schedule shows what that did to every practitioner in Medicare: 24,500 fewer facing a double-digit loss, and 148,700 more facing some loss at all. Dermatologists in the worst band went from 53.5 percent of the specialty to zero.


The CY2027 physician fee schedule final rule runs 2,468 pages and the specialty impact table is not in any of them.

CMS pulled it out this year and posted it as a spreadsheet instead, "in the interest of greater accessibility." That is the table everyone opens first, the one with your specialty and a single percentage next to it, and it is rounded in the source workbook to whole points.

Alongside it sits a second file almost nobody opens, and it is the one with the answer in it.

"The percentages are averages and may not necessarily represent what is happening to the particular services furnished by a single practitioner within any given specialty."

That is CMS, in the rule, about its own table.

The agency's fix is a public use file called Specialty Impacts by Practitioner: every practitioner in Medicare sorted into eleven bands by how much their total RVUs move. It shipped with the July proposal too, so you can difference the two and watch what the comment period bought.

What 30 Points of Climbdown Looks Like

The headline change is modifier 25. CMS proposed paying everything but the highest-valued line at 50% when an office visit lands the same day as a 0-, 10- or 90-day global.

We priced that here on October 11 and called the 50 percent an opening position.

It is finalized at 20%, and only against 0-day globals.

CMS sizes the scope narrowing itself: "the impacts to specialties will be reduced by around 1 percent by limiting this policy to only 0-day global services."

Run the two practitioner files against each other and the whole package, modifier 25 plus the indirect practice cost index removal plus the G2211 swap to modifier B1 at 16 percent, moves like this (chart below).

The band from -20% to -10% held 27,400 practitioners in July. It holds 2,900 now.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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