A podiatrist evaluates a patient’s new complaint and performs a necessary procedure during the same visit. When the evaluation is significant and separately identifiable, Modifier 25 allows the practice to report both services.
That familiar billing process could become considerably less profitable under a proposed Medicare policy for 2027.
What CMS is proposing
Under the proposed 2027 Medicare Physician Fee Schedule, when an office or outpatient E/M visit and a procedure with a 0-, 10-, or 90-day global period are performed on the same day by the same physician or group:
- The highest-valued service would be paid at 100%.
- The remaining procedure or E/M service would be paid at 50%.
CMS describes the proposal as a way to account for efficiencies when multiple services are delivered during the same encounter.
Physician organizations, including the American Podiatric Medical Association, argue that separately identifiable services should continue to receive appropriate reimbursement.
The proposal has not been finalized, but podiatry practices should begin evaluating its potential impact.
Why podiatry may be significantly affected
Same-day evaluations and procedures are common in podiatry. A patient may arrive with one concern but require evaluation of an additional problem, changes to an existing condition, wound assessment, debridement, injection, or another office-based procedure.
If the proposed reduction is finalized, even correctly documented services could receive lower reimbursement.
Documentation would remain essential. However, strong documentation alone would not prevent the proposed payment reduction.
What practices should do now
1. Measure your exposure
Review how frequently your practice reports Modifier 25 with procedures carrying global periods. Calculate the potential effect of a 50% reduction on the lower-valued service.
2. Audit documentation
The medical record should clearly demonstrate why the E/M service was significant and separately identifiable from the procedure.
3. Monitor the final rule
The policy is still proposed. Billing teams should follow CMS and APMA updates before changing workflows.
4. Avoid unnecessary scheduling changes
Patient care should remain the priority. Practices should not separate medically necessary services simply to work around a proposed payment policy.
The practices that prepare early will be better positioned to respond if the rule is finalized.
Beacon Podiatric Billing Services helps podiatry practices monitor reimbursement changes, strengthen claim accuracy, manage denials, and understand the financial impact of evolving payer policies.
Learn more: https://beaconpbc.com/
Source: American Podiatric Medical Association
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