1. Measure
- 2025 Medicare encounters with a modifier 25 office E/M and a same-day global by the same group, per rendering provider
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Insight · CY 2027 Physician Fee Schedule (proposed)
CY 2027 PFS: the same-day E/M and global procedure cut, specialty by specialty
Short answer: CMS proposes to pay only the most expensive service in full when an office E/M and a 0-, 10- or 90-day global procedure share a date and a group, with everything else at 50 percent. Dermatology, otolaryngology and podiatry are named first. Proposed, not final.
CMS-1847-P · issued Jul 14, 2026
Modifier 25 · 0, 10, 90-day globals
Proposed · effective Jan 1, 2027 if finalized
Focus
Same-day E/M + global
Framework
CMS-1847-P
Metric
50% on the rest
Codes
Modifier 25
Effective date
Jan 1, 2027 if finalized
Length
6 min read
50%
Proposed payment for every same-day procedure or office E/M other than the most expensive [2]
-9%
Proposed combined CY 2027 impact on allowed charges for dermatology and otolaryngology [2]
Sep 142026
Comment deadline; final rule expected November [2]
$32.84
Proposed conversion factor, down 1.68 percent from $33.40 [1]
Floated and dropped in 2019, back for 2027
The visit is the one you append modifier 25 to. CMS's rationale: the global package already values E/M-crosswalked pre- and post-service work, so a same-day visit duplicates payment; 50 percent matches the multiple procedure reduction [2]. Comment sought on 25 percent, inpatient E/M, and intravitreal injections such as 67028.
One dermatology visit, 28.7% fewer RVUs
Visit 99212, then shaves 11300 and 11301, at 2026 non-facility RVUs [2]; the conversion factor cut comes on top.
Today
Total non-facility RVUs, 2026 values
113013.48
113002.89
992121.78
Encounter total8.15 RVUs, 100%
Under the proposal
Most expensive 100%, rest 50%
113013.48
113001.445
992120.89
Encounter total5.815 RVUs, -28.7%
Who reports modifier 25 with a global
CMS names otolaryngology, dermatology and podiatry, then hand surgery, physician assistants and colon and rectal surgery. Table D-B5 reflects every proposal in the rule, not the modifier 25 share alone [2].
Table D-B5 excerpt: CY 2027 proposed combined impact on total allowed charges
NF = non-facility, F = facility. CMS attributes the large decreases mainly to modifier 25 and indirect practice cost index removal.
Dermatology$3,881M allowed
-9%NF -9%, F -7%
Otolaryngology$1,199M
-9%NF -10%, F -3%
Orthopedic surgery$3,296M
-7%NF -5%, F -8%
Colon and rectal surgery$147M
-4%NF -9%, F -1%
Podiatry$1,969M
-4%NF -4%, F 0%
Plastic surgery$268M
-3%NF -4%, F -1%
Ophthalmology$4,548M
-3%NF -3%, F -2%
Obstetrics/gynecology$558M
-1%NF -1%, F -2%
Family practice$5,976M
+1%NF +1%, F +3%
0-2.5%-5%-7.5%-10%
-7% or worse-3% to -4%-1%Increase
Where the same-day pattern is common: date of service, rendering NPI and group, CPT with global indicator, modifier 25
| Specialty | Typical same-day pairing | Global period |
|---|---|---|
| Dermatology | Office E/M with 11300 to 11313 shaves, 11400 to 11446 excisions, 17000 to 17111 destructions, 11102 to 11107 biopsies | 0 or 10 day |
| Otolaryngology | Office E/M with 31231 nasal endoscopy, 69210 cerumen removal, 30901 to 30903 epistaxis control | 0 day |
| Podiatry | Office E/M with 11055 to 11057 callus paring, 11719 to 11721 nail debridement, 10060 incision and drainage | 0 or 10 day |
| Orthopedics and hand surgery | Office E/M with 20600 to 20611 joint injections, 20550 to 20553 tendon injections, 29075 to 29125 casting and splinting | 0 day |
| Ophthalmology | Office E/M or eye code with 67028 intravitreal injection | 0 day |
| OB-GYN | Office E/M with 57454 to 57456 colposcopy, 58100 endometrial biopsy, 58300 IUD insertion | 0 or 10 day |
Commercial payers that follow Medicare multiple procedure logic may follow this too: a 2027 renewal question.
Measure, price, audit, load
2. Price
- 100 and 50 percent at 2026 RVUs and $32.84; a board dollar figure, labeled proposed
3. Audit the modifier
- CMS names claims editing, comparative billing reports and medical review as monitors, and calls separate-day scheduling to maximize payment highly problematic
4. Load the final rule in November
- If finalized: dates of service from January 1, 2027
Takeaway
The specialties most exposed are the ones whose visit and procedure are the same appointment. The defense is clean modifier 25 documentation and an exposure number the board has already seen, not a rescheduled patient.
Two moves this week
Pull modifier 25 and same-day global pairs by rendering providerOur dermatology billing and multispecialty group billing teams run it in a week; autonomous coding rules flag modifier 25 visits without separately identifiable documentation before the claim leaves.
Put the January calendar in one placeThe Coding Operator on CPT 2027, the maternity playbook, the urgent care view.
Frequently asked questions
What is the CY 2027 same-day E/M and procedure proposal?
CMS proposes that when a separately identifiable office or outpatient E/M visit is furnished by the same physician or same group practice on the same day as a 0-, 10- or 90-day global procedure, the most expensive service is paid at 100 percent and all other surgical procedures or E/M visits that day at 50 percent. It is proposed for dates of service from January 1, 2027 and is not final until the CY 2027 final rule.
Does the proposal change modifier 25 rules?
No. Modifier 25 still identifies a significant, separately identifiable E/M visit on the day of a procedure. The proposal changes payment for that visit when it is not the most expensive service on the date. CMS also asks for comment on whether conditions of payment should be revised to prevent scheduling services on separate days to avoid the reduction.
Which specialties are most affected?
CMS says the modifier 25 proposal would have the largest negative impact on otolaryngology, dermatology and podiatry, and to a smaller extent hand surgery, physician assistants and colon and rectal surgery. Table D-B5 shows combined proposed impacts of -9 percent for dermatology and otolaryngology and -7 percent for orthopedic surgery, reflecting all proposals in the rule.
Could the reduction be 25 percent instead of 50?
CMS proposed 50 percent to match the longstanding surgical multiple procedure payment reduction, and it asked for comment on whether a different value such as 25 percent would be more appropriate. The final rule will settle it.
- CMS fact sheet, Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (July 14, 2026)
- Federal Register public inspection, CMS-1847-P, CY 2027 PFS proposed rule (published July 16, 2026; comments due September 14, 2026): section on E/M resource overlap between stand-alone visits and global periods, Table D-B5 specialty impacts
Checked October 25, 2026. Rules change; confirm against the source before relying on them. Items marked proposed are not final until the final rule publishes.
Want your same-day E/M exposure measured before the final rule?
We pull your 2025 modifier 25 and global pairs, price them under the proposal and audit the documentation behind the modifier.