Protect Patient Access to Dermatologic Care

I am writing regarding the proposed Medicare policy affecting same-day evaluation and procedures.

Patients should be able to receive timely, medically appropriate dermatologic care. When a dermatologist determines that a suspicious lesion requires a biopsy, completing that biopsy during the same appointment can reduce delays, additional travel, missed work, added expense and anxiety.

Policies that discourage appropriate same-day care would be especially difficult for Medicare patients, rural patients and anyone who must travel a significant distance to see a dermatologist.

I respectfully ask CMS to preserve appropriate payment for a significant, separately identifiable evaluation and management service provided on the same day as a medically necessary procedure.

Please protect patient access to timely dermatologic care.

I work at Ada West Dermatology in Idaho and am submitting this comment as an individual healthcare employee regarding the proposed Medicare policy affecting same-day evaluation and procedures.

In my work, I see patients who are concerned about suspicious lesions and other potentially serious skin conditions. When medically appropriate, completing an evaluation and necessary procedure during the same appointment helps patients receive timely care while avoiding additional travel, missed work, expense and anxiety.

Additional appointments would be particularly burdensome for older adults, rural Idaho residents and patients who already face long waits or travel significant distances for specialty care.

I respectfully ask CMS to preserve appropriate use and payment of Modifier 25 when a significant, separately identifiable evaluation and management service is performed on the same day as a medically necessary procedure.

Please address inappropriate billing through focused oversight without creating barriers to appropriate patient care.

I am a dermatology provider in Idaho and am submitting this comment regarding the proposed Medicare policy affecting payment for evaluation and management services performed on the same day as a procedure.

A significant, separately identifiable evaluation and management service is not interchangeable with the procedural work that follows it. Dermatology visits may involve evaluation of multiple conditions, review of relevant history, examination, differential diagnosis, counseling, treatment planning and medical decision-making beyond the work ordinarily included in a procedure.

When that evaluation identifies a lesion requiring biopsy or another medically necessary intervention, providing appropriate same-day care reduces diagnostic delay and avoids an unnecessary second appointment.

A policy that broadly reduces payment for properly documented services could discourage efficient care and disproportionately burden older adults, rural patients and communities with limited access to dermatologists.

I respectfully ask CMS not to finalize a policy that reduces payment for appropriately documented, separately identifiable evaluation and management services. Targeted auditing and documentation enforcement would address improper billing without penalizing medically necessary care.

I am asking you to support policies that protect patients’ ability to receive timely, medically appropriate dermatologic care.

Dermatologists frequently evaluate suspicious lesions and determine that a biopsy or another procedure is medically necessary. When appropriate, providing that care during the same visit reduces delays, unnecessary appointments, additional travel, missed work and patient expense.

Medicare policies that discourage appropriate use of Modifier 25 could create barriers for older adults, rural Idaho residents and other patients with limited access to specialty care.

Please ask CMS to preserve appropriate payment for significant, separately identifiable evaluation and management services provided on the same day as medically necessary procedures.

Thank you for protecting timely access to high-quality dermatologic care.