Ver esta página en español →

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.

comments filed so far — and counting
left to comment — closes Sept 14, 11:59 PM ET

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.

Use your own words. Regulators tend to group and count identical form-letter comments as one, while a specific, personal comment carries real weight — and federal rules require that a comment be filed by the person it’s actually from, not submitted in bulk on someone’s behalf. The checklist below is there to help if you’re not sure what to say; even one added sentence in your own words makes your comment count more.
Who you are
Your comment
Review & submit
I am…

Also called things like incision and drainage (I&D), cryotherapy, electrodesiccation and curettage (ED&C), or excision — pick whichever is closest to what happened.

Checking a box above adds a starter sentence here. Edit it, delete it, or add your own. A blank form-letter comment doesn’t carry weight; a few sentences that sound like you do.

Regulations.gov comments are public record, so don’t include private patient information.

Regulations.gov will also ask for your name when you submit — this just adds it to the letter itself, which reads as more genuinely yours with one attached. Leave it blank to stay unsigned here.

Your comment

What you’ll see next

The real Regulations.gov page you'll land on, with the blue Comment button highlighted near the top left, below the rule's title

That’s the real page — look for the blue “Comment” button (circled above), just below the rule’s title. Click it, paste your comment in, and submit.

This copies your comment and opens the official Regulations.gov form in a new tab — paste it in and submit. That submission is yours, filed under your own name, not ours. Reference file code CMS-1848-P if asked.