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Physician Action Toolkit

Protect Your Patients.
Protect Access to ENT Care.

CMS has proposed changes that would cut same-day ENT reimbursements and restrict access for the patients who need us most. Your voice as a physician carries real weight. Here's how to use it.

Simple steps. Powerful impact.
⚠️  Public Comment Deadline: September 14, 2026 — Act now before the window closes.  Submit Your Comment →
Key Dates
Jul 14, 2026 CMS Proposed Rule Released
Sep 14, 2026 Public Comment Deadline
Fall 2026 CMS Reviews Comments
Jan 1, 2027 Proposed Implementation

Every Physician Voice Helps.

The proposed 2027 Medicare Physician Fee Schedule would directly impact how you deliver ENT and allergy care. Take action below — it takes less than 10 minutes.

What's Actually Being Proposed — and Why It Matters

CMS has released a proposed rule that would cut reimbursement for same-day evaluation and treatment — the fundamental workflow of ENT practice. Here's what you need to know.

−9%
Estimated ENT specialty RVU reduction in CY2027 — one of the two largest cuts of any specialty
Conversion factor decline is applied on top of this figure
50%
Payment rate for the secondary service when a procedure and E&M visit occur on the same day
Currently paid at 100% — the proposed cut is immediate and significant
Sep 14
Public comment deadline — the only window to influence the final rule before November
Final rule expected ~November 1, 2026 · Effective January 1, 2027

This Has Been Stopped Before — And It Can Be Again

CMS proposed nearly identical Modifier 25 cuts in the CY2019 Physician Fee Schedule. After a strong response from specialty societies during the public comment period, CMS withdrew the proposal entirely. Your comments directly contributed to that outcome. This year's comment deadline is September 14 — and the same opportunity exists right now.

🔬 How the Proposed Cut Works

  • When you bill an office E&M visit on the same day as a procedure with a 0-, 10-, or 90-day global period, only the highest-value service is paid at 100%
  • Every additional service billed that day — including the E&M — is paid at 50 cents on the dollar
  • CMS argues this avoids "duplicate payment" — but the E&M must already meet the "significant and separately identifiable" standard to be billed at all
  • CMS is also soliciting comment on extending the policy to inpatient and other E&M families
  • The conversion factor itself also declines: −1.19% for APM participants, −1.68% for all others — on top of the RVU hit

👂 Why ENT Is Hit Hardest

  • The cut targets a workflow — evaluate, diagnose, treat in one visit — that is the standard of care in ENT
  • Procedures commonly performed same-day include: nasal endoscopy, flexible laryngoscopy, cerumen removal, sinus debridement, biopsy, control of epistaxis, in-office tympanostomy
  • Every one of these carries a global period, making the same-day E&M billable with Modifier 25 — and now exposed to the cut
  • Allergy testing and immunotherapy codes do not carry global periods and are largely insulated from this proposal
  • CMS explicitly names otolaryngology and dermatology as the two specialties facing the largest negative impact
Specialty Estimated CY2027 RVU Impact Primary Driver
Otolaryngology (ENT) Approx. −9% Same-day E&M + in-office procedure
Dermatology Approx. −9% Same-day E&M + lesion procedure
Orthopedic Surgery Approx. −7% Same-day E&M + injection or casting
Hand Surgery Approx. −5% Same-day E&M + procedure
Clinical Psychology Approx. +11% Redistribution of RVUs
Clinical Social Work Approx. +12% Redistribution of RVUs
Source: CY2027 PFS proposed rule regulatory impact analysis, Table D-B5. RVU impacts shown before conversion factor reduction.

⚠️ The Medicare Cut May Be the Smaller Risk

Commercial payers have historically followed CMS on multiple procedure payment reductions and E&M downcoding — often adopting similar policies in their next contracting cycle. If this rule is finalized, commercial payers may implement equivalent edits as early as 2028. The full financial exposure for SENTA network physicians could be substantially larger than the Medicare-only figures above.

1

Contact Congress

Send a personalized letter to your U.S. Representative and Senators urging them to oppose the proposed Modifier 25 payment cuts and reductions that threaten same-day ENT care.

⏱ About 5 minutes
✍ Write My Letter
2

Submit a CMS Comment

CMS is accepting public comments through September 14, 2026. Personalized physician comments carry significant weight. Submit yours directly to the federal docket.

⏱ About 5 minutes
✍ Submit CMS Comment
3

Engage Your Network

Amplify the message with colleagues, professional organizations, and on social media. The more physician voices speaking up, the harder it is for CMS to ignore.

#ProtectPatientAccess #SaveSpecialtyCare #ENTAdvocacy #SENTACares
Share on LinkedIn
4

Share a Patient Story

Real clinical examples are the most powerful advocacy tool we have. If you have a patient case that shows what these cuts would mean in practice, we want to hear it.

⏱ Just a few minutes of your time
📩 Share Your Story
✍️

Write & Send Your Letter

Fill in your information, choose your target, and we'll generate a personalized letter. Edit it freely — then send directly to Congress or submit to the official CMS docket.
Your Letter — Review & Edit Before Sending ✏️ Click anywhere in the letter to edit
SENTA physician with patient

Your Story Could Shape Policy

Compelling advocacy starts with real experiences. If you have a patient case or practice example that illustrates what these proposed payment changes would actually mean — on access, timing, and outcomes — your story may help inform our outreach to CMS, legislators, and coalition partners.

Send Your Story to SENTA