Q&A: Practices brace for modifier 25 cuts with anxiety, questions

by Richard Scott on Oct 9, 2026
The latest issue of Part B News returns to a topic that is currently roiling the provider community: CMS' proposal to slash fees for modifier 25-appended claims by up to 50% for some services. The proposal, as recent analysis shows, has massive billing and payment implications.
 
To get a better sense of how providers are grappling with the 25-related angst, Part B News touched base with Greg Field, CEO of Jiro Health, which recently published an analysis of the proposal’s potential financial impact. Field says that anxiety is taking hold and questions are swirling as practices brace for the final 2027 Medicare physician fee schedule -- and what it may or may not confirm for billing and payment policy in CY 2027.
 
Jiro Health, a public benefit corporation that builds practice intelligence for clinicians and practices, is offering free, one-to-one impact briefings to help practices understand their potential exposure. The Q&A is below.
 

Part B News: What are you hearing from practices with regard to CMS’ modifier 25 proposal?
 
Field: "The biggest thing we are hearing is anxiety. Even very sophisticated practices are having a hard time figuring out what the proposal would mean for them. They are trying to understand the total financial impact, which providers and services would be hit hardest, and what they may need to change before 2027.
 
"Most simply do not have that visibility today. The national numbers may get their attention, but they need to understand their own exposure. National figures provide context, but they cannot tell an individual practice which providers, services and encounter patterns are driving its exposure."
 
PBN: How significant could the impact be?
 
Field: "For some groups, it could be very significant. Our modeling shows many practices facing substantial six-figure annual reductions.
 
"Nationally, we estimate $889 million in annual payment reductions, including $395.4 million tied to dermatology, $83 million to orthopedics and $82.2 million to otolaryngology. But the specialty totals do not tell the whole story. Two practices in the same specialty can face very different impacts depending on their Medicare volume, service mix and same-day encounter patterns.
 
"That does not mean every practice is facing a crisis. It does mean practices should understand their own numbers now and revisit them when CMS publishes the final rule."
 
Previous reporting showed that providers are extremely concerned about the direction of the modifier 25 billing and payment restrictions, according to a review of thousands of comments submitted to CMS during the proposed fee schedule comment period. The final fee schedule is expected to be released around Nov. 1.
 
For more data analysis, check out the latest benchmark of the week, "Nearly $900M reallocation at stake over modifier 25 proposal: Analysis" (subscription required), or visit Jiro Health's modifier 25 facts and figures here: https://jirohealth.com/reports/modifier-25-analysis.pdf. 
 

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