CMS Modifies Multiple Services Pay Cut

In response to stakeholder feedback, CMS modified its proposal to reduce reimbursement when certain evaluation and management (E/M) services are billed on the same day as a procedure in the Calendar Year 2027 Medicare Physician Fee Schedule final rule.

Under the proposed policy, CMS would have paid the highest-valued service at 100% and reduced payment for other eligible services provided on the same day to 50% when an office or outpatient E/M visit is reported with a procedure that has a 0-, 10-, or 90-day global period. In response to the proposal, ACR® joined an American Medical Association (AMA)-led, multi-specialty sign-on letter urging CMS to withdraw the proposed payment reduction policy. 

According to CMS, the proposal was intended to address what the agency views as overlapping physician work and resources when an E/M service and a procedure are provided to the same patient on the same day by the same physician or by a physician in the same practice. CMS believes the current payment system may result in duplicate payment in some cases.

In the final rule, CMS agreed with stakeholders that some resource overlap is already accounted for through the Relative Value Scale Update Committee process and as such, modified the reduction policy to 20 percent. CMS stated that a 20 percent reduction is responsive to commenters and “strikes a balance between paying more accurately for services performed on the same day and the real-world impact of the policy.”

In addition, CMS agreed with commenters that resources involved in 10- or 90- day global services occur throughout the global period, making the overlap difficult to quantify. Therefore, CMS will only apply the final policy to E/M visits billed on the same day as 0-day global procedures. Finally, CMS amended the policy to clarify that it applies only to the same physician or physician in the same specialty in the same group practice as opposed to any physician in the same group practice.

For more information, contact Katie Keysor, ACR Vice President of Economic Policy.