Public Comment Period — Closes September 14, 2026
Tell Medicare how this rule would affect your care
CMS has proposed cutting Medicare payment in half for the office visit that leads to a same-day skin biopsy, lesion removal, or other routine procedure. In dermatology, that same-day pattern isn’t the exception — it’s how most suspicious lesions get caught and treated. Public comment on the rule (CMS-1848-P) is open now. Here’s how to file yours.
What CMS-1848-P would change
The Centers for Medicare & Medicaid Services has proposed applying its “multiple procedure” payment rule to office visits billed with modifier 25 on the same day as a procedure with a 0-, 10-, or 90-day global period. In practice: when a visit and a same-day procedure are billed together, Medicare would pay the more expensive of the two in full — and the other at just 50% of the normal rate.
For most specialties this is a narrow provision. For dermatology, it lands squarely on routine care: a patient comes in for a concerning spot, and the dermatologist biopsies, freezes, or removes it during that same visit rather than asking the patient to come back. That’s the standard of care precisely because it catches skin cancer earlier and spares patients an extra trip. A rule that pays less for doing it this way risks pushing care toward unnecessary follow-up visits — more delay and more cost for patients, not less.
This page is an independent tool built by LIDS to help members, patients, and colleagues file their own comments. It doesn’t submit anything on your behalf, and it isn’t affiliated with CMS or Regulations.gov.
- Rule
- CY 2027 Medicare Physician Fee Schedule Proposed Rule
- File code
- CMS-1848-P
- Docket
- CMS-2026-2377
- Comment period closes
- September 14, 2026, 11:59 PM ET
- Where to read it
- Full text on Regulations.gov →
- CMS fact sheet
- CMS.gov summary →
- For your practice
- Print a waiting-room flyer →
Build your comment
This tool helps you put your own comment into words. It doesn’t file anything for you — the last step hands you a ready-to-paste comment and a link to Regulations.gov, where you submit it yourself, in your own name.