FSR Urges CMS to Withdraw Proposed Modifier 25 Payment Reduction

The Florida Society of Rheumatology (FSR) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) opposing a proposed reduction in Medicare payment for Evaluation and Management (E/M) services reported with Modifier 25.

Modifier 25 allows physicians to report a significant, separately identifiable E/M service provided on the same day as a procedure. FSR emphasized that these services represent legitimate physician work and are already subject to documentation requirements, audits, and potential recoupment.

The proposed reduction could have a significant impact on rheumatology practices, where procedures such as joint, tendon sheath, bursal, and trigger point injections are often performed during visits that also require complex evaluation and management of chronic rheumatic diseases.

FSR expressed concern that reducing reimbursement could discourage comprehensive same-day care, increase administrative burdens and unnecessary return visits, delay treatment, and further strain access to rheumatology care, particularly in rural and underserved areas.

FSR is asking CMS to:

• Withdraw the proposed Modifier 25 payment reduction.
• Continue recognizing the physician work involved in separately identifiable E/M services performed with procedures.
• Work with specialty organizations, including the American College of Rheumatology and Coalition of State Rheumatology Organizations, on evidence-based solutions to concerns regarding Modifier 25 utilization.

FSR will continue advocating for payment policies that support access to specialty care, appropriate physician reimbursement, and high-quality care for patients with rheumatic diseases.

Read the letter to CMS.