ASE Joins Comments on the CY 2027 Medicare Physician Fee Schedule Proposed Rule

On September 1, ASE joined the Alliance of Specialty Medicine in comments to CMS Administrator Mehmet Oz on the CY 2027 Medicare Physician Fee Schedule proposed rule. The letter raises cross-specialty concerns about the conversion factor reduction, indirect practice expense methodology changes, the site-of-service payment differential, and, most forcefully, a proposed 50% payment cut for separately identifiable E/M services furnished on the same day as a procedure using modifier -25, which the Alliance calls for CMS to withdraw entirely. The letter also opposes premature coding and payment for shared medical appointments and health coaching, raises concerns about the redesigned G2211 payment methodology, and urges CMS to keep MVP reporting voluntary given persistent gaps in specialty-specific quality measures.

This letter complements ASE’s own detailed comments on the same rule by presenting a unified specialty-medicine front on structural payment issues that affect echocardiography practices alongside other specialties, particularly the practice expense methodology and site-of-service policies that determine how sustainably echo labs can be staffed and equipped. The modifier -25 opposition is especially relevant to cardiology practices, where same-day E/M and diagnostic services are common, and the Alliance’s shared position on preserving voluntary MVP reporting reinforces ASE’s own request that CMS not force echocardiographers into a quality framework where no measure yet reflects the care they provide.