What Is the Proposed Modifier 25 Payment Cut for Podiatry?
As of July 2026, the CMS CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) includes a provision that would reduce Medicare payment by 50% on any E/M visit billed with modifier 25 on the same day as a procedure with a global period. For podiatry, where the majority of office visits involve a same-day procedure such as nail debridement, injection, or wound care, this proposed cut strikes at the core of daily revenue.
What gets cut:
The lower-paid service on a same-day claim drops to 50%. In most podiatry encounters, the E/M visit is the lower-paid service, so the E/M reimbursement is halved while the procedure is paid at 100%.
Who it hits hardest:
Podiatry is one of the specialties with the highest modifier 25 volume because nail debridement, wound care, and injections are routinely performed alongside a separately identifiable E/M visit.
Comment deadline:
The 60-day public comment period closes September 14, 2026. The final rule is expected in November 2026. If finalized, the reduction takes effect January 1, 2027.
What CMS Proposed on July 14
On July 14, 2026, CMS published the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P). The rule proposes that when a physician or another physician in the same group practice furnishes a separately identifiable E/M visit on the same day as a procedure carrying a 0, 10, or 90-day global period, Medicare would pay the most expensive service at 100% and reduce every other service on the claim to 50%. Modifier 25 is the flag that tells Medicare the E/M was significant and separately identifiable from the procedure, making this the textbook scenario for the reduction.
CMS first proposed a narrower version of this cut in 2019 but withdrew it after strong opposition. The 2027 proposal is broader, applying across all global period lengths and reducing the lesser service regardless of whether it is the E/M or the procedure. For podiatry, the E/M is almost always the lesser service, which means the E/M gets halved.
This is a proposed rule, not a final rule. CMS could modify, narrow, or withdraw the provision in the final rule expected this November. But the policy signal is clear: CMS views same-day E/M plus procedure billing as an area of persistent overvaluation.
How Does the Modifier 25 Cut Affect Podiatry Specifically?
Podiatry is disproportionately affected because the specialty’s daily workflow depends on billing an E/M visit alongside a same-day procedure. A patient who comes in for a nail debridement and the podiatrist also evaluates a new complaint, adjusts a treatment plan, or addresses a complication is a standard encounter. Under current rules, both services are paid at their full fee schedule amount when modifier 25 is properly documented. Under the proposal, the E/M drops to 50%.
Here is what the revenue impact looks like on the code pairs podiatry practices bill most frequently:
| Code Pair | Procedure | E/M Level | Current E/M Payment | Proposed E/M Payment | Per-Encounter Loss |
|---|---|---|---|---|---|
| 99213 + 11721 | Nail debridement (6+ nails) | Level 3 established | ~$92 | ~$46 | ~$46 |
| 99213 + 11055 | Paring single lesion | Level 3 established | ~$92 | ~$46 | ~$46 |
| 99214 + 20610 | Joint injection | Level 4 established | ~$128 | ~$64 | ~$64 |
| 99213 + 11730 | Nail avulsion | Level 3 established | ~$92 | ~$46 | ~$46 |
| 99213 + 97597 | Wound debridement | Level 3 established | ~$92 | ~$46 | ~$46 |
A podiatrist seeing 20 of these encounters per week at the 99213 + 11721 pairing alone loses approximately $920 weekly, which compounds to over $47,000 annually from a single code pair. Practices that bill multiple procedure types with modifier 25 on the same day see the losses stack. For a reference on how these codes and modifiers work together in podiatry, see our podiatry billing and coding cheat sheet.
The proposed modifier 25 reduction hits podiatry harder than almost any other specialty because same-day E/M plus procedure billing is how podiatry practices operate every day.
If your billing team is not already modeling the revenue impact of CMS-1848-P on your top code pairs, a billing partner who knows podiatry can run that analysis before the final rule drops. Get matched with vetted podiatry billing companies, free.
What Should Podiatry Practices Do Now?
These steps protect your revenue before the final rule publishes.
- Pull your modifier 25 volume report. Identify every code pair where modifier 25 appeared on a Medicare claim in the last 12 months. The 99213 + 11721 and 99213 + 11055 pairs will likely represent the highest volume.
- Calculate your annual exposure. Multiply the E/M allowed amount by 0.50, then multiply by your annual volume for each code pair. That total is your maximum annual revenue at risk.
- Review your documentation standards for modifier 25. The documentation must show that the E/M was significant and separately identifiable from the procedure. A note that says "patient here for nail care, also discussed diabetes management" needs to clearly separate the two evaluations with distinct chief complaint, exam, and medical decision making.
- Submit a public comment to CMS by September 14. Comments can be submitted at regulations.gov under docket CMS-1848-P. Include your practice’s modifier 25 volume data and the dollar impact. CMS pulled back the 2019 version after public comment, so this step matters.
- Evaluate whether your billing company has flagged this change. In our experience matching podiatry practices with billing partners, the billing companies that protect revenue most effectively are the ones monitoring CMS proposed rules before they become final. If your current partner has not raised CMS-1848-P with you, that gap in regulatory awareness is worth addressing now.
- Do not stop billing modifier 25. This is a proposed rule, not an effective rule. Modifier 25 remains valid and necessary for same-day E/M encounters. Practices that preemptively stop billing modifier 25 are giving up revenue today based on a rule that may never be finalized in its current form.
Common Misreadings of This Proposal
One question we hear constantly from podiatry practice managers is whether this means they can no longer bill an E/M with a nail debridement. That is not what the proposal says. Modifier 25 still exists, the E/M is still separately reportable, and the documentation requirements are unchanged. What changes is the reimbursement on the lesser service, not the ability to bill it.
The second common misreading is that the 50% cut applies to the procedure. In most podiatry encounters, the E/M is the lower-paid service. The procedure, such as 11721 or 20610, is typically paid at the higher rate and would remain at 100%. The E/M gets halved, not the procedure.
The third mistake is assuming this only affects Medicare. While the proposed rule applies directly to Medicare fee-for-service, commercial payers routinely align their payment policies with CMS methodology within 12 to 24 months. A finalized Medicare change on modifier 25 creates a blueprint that commercial plans can and likely will adopt. Podiatry practices whose payer mix includes substantial commercial volume should not assume they are insulated from a Medicare-only change.
Frequently Asked Questions
No. This is a proposed rule published July 14, 2026 (CMS-1848-P). The comment period closes September 14, 2026. If finalized without changes, the reduction would take effect January 1, 2027. CMS could modify or withdraw the provision in the final rule expected this November.
The highest-volume affected pairs for podiatry are 99213 + 11721 (nail debridement), 99213 + 11055 (lesion paring), 99214 + 20610 (joint injection), 99213 + 11730 (nail avulsion), and 99213 + 97597 (wound debridement). Any encounter that pairs an E/M with a procedure carrying a global period is within scope.
No. The proposal does not eliminate modifier 25 or change its documentation requirements. The E/M visit is still separately reportable when it is significant and separately identifiable from the procedure. What changes is the reimbursement amount on the lesser service, not the ability to submit the claim.
A practice that bills 20 modifier 25 encounters per week at the 99213 + 11721 pairing loses approximately $46 per encounter, which totals roughly $47,000 per year from a single code pair. Practices billing multiple procedure types with modifier 25 see compounding losses that can reach six figures annually.
No. This is a proposed rule, not a finalized rule. Modifier 25 remains valid and necessary for same-day E/M encounters where the evaluation is significant and separately identifiable. Practices that preemptively stop billing modifier 25 forfeit revenue today based on a rule that has not taken effect.
Commercial payers are not bound by the CMS proposed rule, but they frequently benchmark their payment policies against Medicare methodology. A finalized Medicare reduction on modifier 25 often becomes a commercial payer audit trigger or payment policy change within 12 to 24 months.
Next Steps
- Run a modifier 25 volume report on your Medicare podiatry claims and calculate the dollar exposure on your top five code pairs.
- Submit your comment to CMS at regulations.gov (docket CMS-1848-P) before September 14, 2026, with your practice’s specific data.
- If your billing company has not flagged this proposed rule for your practice, consider whether a podiatry billing specialist would better protect your revenue. Podiatry Bill Co matches foot and ankle practices with billing companies that track CMS rulemaking and model the impact before it becomes a billing surprise.
The modifier 25 reduction would hit podiatry revenue on the encounters you bill every single day.
Do not wait for the final rule to find out how much your practice stands to lose. Get matched with podiatry billing companies that already know CMS-1848-P and can model the impact on your code mix today. Podiatry Bill Co is powered by Billing Service Quotes, which has connected more than 2,000 providers across all 50 states with over 15 years in medical billing. Finding a match is 100% free.
