SKNV’s Call to Action in Solidarity with their Dermatologists: CMS Wants to Cut What Dermatologists Get Paid for Same-Day Procedures
Every dermatologist knows the moment: a patient comes in for a routine visit, and during the exam the dermatologist spots something that needs to come off, a suspicious lesion, a wart, a cyst. The dermatologist biopsies it. The dermatologist treats it. That’s not two unrelated events billed opportunistically. That’s good medicine, delivered efficiently, in a single visit instead of two.
The Centers for Medicare & Medicaid Services (CMS) wants to make that efficiency cost dermatologists money.
What CMS Is Proposing
Buried in the CY 2027 Medicare Physician Fee Schedule proposed rule, released July 14, 2026, is a policy that would fundamentally change how same-day office visits and procedures are reimbursed. Under current rules, Modifier 25 allows a physician to bill separately for a significant, distinct E/M visit performed the same day as a procedure, recognizing that the office visit and the procedure are two different services requiring two different sets of clinical judgment and work.
CMS’s new proposal would pay only the higher-priced of the two services at 100%. Everything else performed that same day, the other E/M visit, the biopsy, the destruction, the injection, would be paid at just 50%.
Here’s what that looks like in practice. An office visit priced at $120 combined with a biopsy priced at $100 currently totals $220 in reimbursement. Under the proposed rule, that same encounter would total $170 in reimbursement, a lost revenue of $50 per encounter.
Multiply that across a single dermatology practice’s daily volume of biopsies, lesion destructions, and injections, and the math becomes brutal. This isn’t a rounding error in a fee schedule. It’s a direct hit to the economics of how dermatology is practiced.
Why Dermatology Is Ground Zero
CMS’s own analysis acknowledges that this proposal will disproportionately harm a small number of specialties, and dermatology sits at the top of that list, alongside otolaryngology and podiatry. That’s not a coincidence. It’s because dermatologists routinely and appropriately combine E/M visits with procedures in the same encounter. That’s not gaming the system. That’s what efficient, patient-centered dermatologic care looks like.
CMS frames this as eliminating duplicate payment for E/M work supposedly already baked into the procedure’s global period. Practicing dermatologists know better: the decision-making that goes into diagnosing a lesion is not the same work as the decision-making that goes into deciding how and whether to biopsy it, and neither is captured twice just because they happen on the same calendar day.
The Stakes Go Beyond the Balance Sheet
For practices where physician compensation is tied to collections, this proposal doesn’t just squeeze the practice, it squeezes the people who took the time to build a specialty around precision, judgment, and same-visit efficiency for their patients. It penalizes the exact behavior that should be encouraged: getting patients diagnosed and treated in one visit instead of dragging them back for a second appointment.
And once CMS sets this precedent for dermatology, there is little reason to believe it stops there.
This Is Still a Proposal, Which Means There’s Still Time
This policy is not finalized. It would not take effect until January 1, 2027, and CMS is required to consider public comments before issuing a final rule. The comment period closes September 14, 2026.
CMS has explicitly invited feedback on whether the reduction should be smaller, for example, 25% instead of 50%, which signals that the agency knows this number is not settled. That’s an opening. It’s also an admission that the number was chosen with limited real-world input from the physicians who will absorb the cut.
A Common Cause
Dermatology practices report the operational and financial pressure already facing the specialty on a weekly basis. This proposal adds to it substantially, and it deserves the same scrutiny and pushback the specialty has mounted against other reimbursement threats.
SKNV builds custom-manufactured therapeutics for dermatologists because it believes in supporting the specialty’s ability to practice medicine on its own terms, not on terms dictated by a fee schedule formula that doesn’t reflect the complexity of same-day clinical decision-making. On this issue, SKNV stands with dermatologists, not because it is convenient, but because the proposal is wrong on the merits.
SKNV is urging every dermatology practice to submit a comment to CMS before September 14, 2026. Specificity matters: real encounter data, real financial impact estimates, and real patient-care examples carry more weight than general objections. Practices that need help quantifying the impact of this rule on their specific patient mix and procedure volume are welcome to reach out for assistance.
The comment period is short. The impact, if this rule is finalized as written, will not be.