ABA Advocates for Fair Medicare Payment Under the Proposed CY 2027 Physician Fee Schedule
Monday, August 31, 2026
In this article, you’ll learn
Why the American Burn Association (ABA) signed on to a coalition letter urging Centers for Medicare & Medicaid Services (CMS) to withdraw a proposed 50% Medicare payment reduction. View the letter.
How the proposed policy could affect separately identifiable evaluation and management services reported with modifier -25 on the same day as certain procedures.
Why ABA and other physician organizations are calling for a targeted, evidence-based approach to addressing potential payment overlap.
How the policy could affect burn care practices and patient access to care.
Introduction
The Centers for Medicare & Medicaid Services (CMS) has proposed a significant change to Medicare payment for certain services furnished during the same patient encounter. Under the proposed policy, when a separately identifiable office or outpatient evaluation and management (E/M) service is reported with modifier -25 on the same day as a procedure with a 0-, 10-, or 90-day global period, CMS would pay the highest-valued affected service at 100% and reduce payment for the other affected service or services by 50%.
The American Burn Association (ABA) signed on to a coalition letter urging CMS not to finalize the proposal. The letter raises concerns about the lack of evidence supporting a uniform 50% reduction, the potential duplication of adjustments already incorporated into Medicare payment rates, and the policy's potential effect on independent physician practices and patient access.
For burn care professionals, same-day evaluation and procedural care may be clinically necessary and more efficient for patients. ABA is participating in this advocacy effort to ensure that Medicare payment policies accurately reflect physician work and resources required to provide patient care.
What is CMS proposing?
Currently, modifier -25 is reported when a physician or qualified healthcare professional provides a significant, separately identifiable E/M service on the same day as another procedure or service. The use of the modifier indicates that the E/M service involved work that was beyond the routine evaluation included in the procedure.
Under the proposed CY 2027 policy, when an office or outpatient E/M service reported with a modifier -25 and a procedure with a 0-,10-, or 90-day global period are furnished on the same day by the same physician or group practice, the highest-valued affected service would be paid at 100% and other impacted service(s) would be paid at 50%. Depending on the services provided, the reduction in payment could apply to either E/M services or procedures. CMS' goal is to prevent overlapping services during the same encounter.
Why is ABA concerned about the proposed reduction?
ABA and the other organizations signing the coalition letter believe CMS should provide stronger evidence before justifying payment reduction across a broad range of services and specialties.
The letter asks CMS to address several questions:
What specific physician work, clinical labor, supplies, equipment, or other resources does CMS believe are duplicated?
What evidence demonstrates that this overlap occurs consistently across affected services?
Why would any identified overlap warrant a 50% reduction in payment?
What evidence or circumstances have changed since CMS considered and declined a similar policy in 2019?
How would the proposal affect independent physician practices and beneficiary access, especially in rural and underserved communities?
The letter notes that the proposed reduction would apply to the full value of the lower-paid service, including physician work, practice expenses, and professional liability expenses. CMS has not demonstrated that duplication occurs across each of those payment areas.
The organizations also note that Medicare's existing valuation processes already account for resource overlaps when E/M services are commonly performed together. Applying another uniform reduction could reduce payment a second time for resources already accounted for.
What does the proposal mean for burn care professionals?
The field of burn care shows why a same-day E/M service and procedure may involve distinct and medically necessary physician work.
To properly treat a burn survivor, a physician may need to:
Evaluate graft compromise or infection before performing debridement.
Reassess an evolving burn wound before determining whether excision or another procedure is appropriate.
Evaluate a contracture or functional deterioration before performing a wound or scar-related procedure.
Assess a new wound, complication, or change in the patient’s overall condition that is separate from the technical work of the procedure.
Physicians must evaluate, using their independent clinical judgment, whether a procedure should be performed, delayed, or modified. Burn procedures are not part of the routine pre-service work already included in the procedure's payment.
CMS is also seeking comments on whether to apply a similar policy to inpatient E/M services. The possible extension also concerns burn care. Inpatient burn management may include assessment of fluid status, airway injury, infection, pain control, nutrition, and multidisciplinary treatment on the same day that a bedside procedure is performed. These services address the patient’s broader medical condition and should not be presumed duplicative of the procedure.
A broad payment reduction could also create pressure to separate clinically related services across multiple visits. This change would increase the burden on patients who already travel significant distances to receive specialized burn care.
What alternative approach is ABA supporting?
Rather than applying a broad payment reduction to affected services, ABA and the other organizations are asking CMS to use established valuation processes to identify and address demonstrated instances of duplication.
These processes include:
The AMA/Specialty Society RVS Update Committee process.
CMS’s potentially misvalued-code review.
National Correct Coding Initiative edits.
Targeted medical review.
Provider education and existing documentation requirements.
A targeted approach would allow CMS to identify services where evidence shows payment does not appropriately account for overlapping resources. This approach would also allow the agency to adjust only the payment components where duplication is actually present.
What does this mean for burn care professionals?
Medicare payment policy is one component of the broader environment in which burn care is delivered. Changes to physician reimbursement can affect the financial sustainability of practices and the resources available to provide care.
By signing on to the letter, ABA is working with other physician organizations to raise concerns about a policy that could affect physicians and practices providing Medicare-covered services.
ABA's position is that any adjustment to Medicare payment should be evidence-based and accurately reflect the resources required to deliver care.
Key Takeaways
ABA signed on to an AMA led letter asking CMS to withdraw the proposed 50% payment reduction.
CMS would pay the highest-valued affected service at 100% and reduce payment for the other same-day affected service(s) to 50%.
The proposal applies to office and outpatient E/M services reported with modifier -25 alongside procedures with 0-, 10-, or 90-day global periods.
CMS is seeking comments on extending the policy to other E/M categories, including inpatient services.
The coalition letter questions the evidence supporting a uniform 50% reduction and asks CMS to explain the basis for the policy.
Independent, office-based practices could be particularly affected because they bear the costs of clinical staff supplies, equipment, and administrative support.
ABA supports a targeted, evidence-based approach to addressing the demonstrated payment overlap.
Expert Perspective
“A policy of this scope should be based on demonstrated duplication in identified services, rather than an assumption that resources are likely to overlap.”
Source: Letter signed by the American Burn Association and other physician organizations to CMS, August 27, 2026.
The letter also calls on CMS to consider the proposed policy's potential effects on independent physician practices and beneficiary access, particularly in rural and underserved communities.
Resources
CMS CY 2027 Physician Fee Schedule Proposed Rule — Provides background on the proposed Medicare payment policies, including the proposed treatment of E/M services reported with modifier -25.
ABA Advocacy — Provides information about ABA's efforts to represent the interests of burn care professionals and engage on policies affecting burn care.