Private Practices Would Bear 80% of the Nearly $1B Impact of CMS's Modifier 25 Proposal

In the news release, Private Practices Would Bear 80% of the Nearly $1B Impact of CMS's Modifier 25 Proposal, issued 24-Sep-2026 by Jiro Health over PR Newswire, we are advised by the company that changes have been made. The complete, corrected release follows, with additional details at the end:

Jiro's analysis of Medicare claims finds the impact concentrated in six specialties, with dermatology alone accounting for nearly $400 million.

AUSTIN, Texas, Sept. 24, 2026 /PRNewswire/ -- A new analysis from Jiro Health estimates that a proposed change to Medicare payments involving Modifier 25 would reallocate approximately $889 million in annual Medicare fee-for-service payments, with 81.5% of the modeled reductions tied to private practices and solo physicians.

The findings are detailed in Jiro's new Practice Impact Analysis, Who Pays for CMS's Modifier 25 Proposal?, which uses real-world Medicare claims data to examine how the Centers for Medicare & Medicaid Services' proposed policy would affect different specialties and practice settings.

Under the proposed 2027 Medicare Physician Fee Schedule, when a separately identifiable office or outpatient evaluation and management service is provided on the same day as a procedure with a 0-, 10- or 90-day global period, CMS would pay the highest-valued service in full and reduce each other qualifying service by 50%.

Jiro's analysis finds that the financial effects would be highly concentrated:

• Approximately $889 million in annual Medicare fee-for-service payments would be reallocated.
• Private practices and solo physicians account for $724.4 million, or 81.5%, of the modeled reductions.
• Six specialties account for approximately $732 million, or 82.3%, of the total modeled reductions.
• Dermatology alone accounts for $395.4 million, or 44.5% of the total.
• Podiatric medicine and surgery, orthopaedic surgery, otolaryngology, ophthalmology and family medicine account for an additional approximately $336 million combined.

"This proposal is often discussed as a technical payment change. The data shows something much larger: a nearly $1 billion annual impact concentrated among private practices and a small number of specialties," said Greg Field, CEO of Jiro Health. "Real-world data gives clinicians and policymakers a clearer view of who would absorb the change before it takes effect."

Modifier 25 indicates that a significant, separately identifiable evaluation and management service was provided on the same day as another procedure. Physician organizations and specialty groups have argued that reducing payment could undervalue medically necessary work performed during the same encounter.

CMS's public comment period closed September 14. Jiro's review of the public docket identified more than 10,000 comments referencing Modifier 25, with roughly 85% containing explicit language opposing the proposal. CMS is expected to issue the final 2027 Physician Fee Schedule this fall. Any finalized changes would take effect January 1, 2027.

Turning National Policy Into Practice-Level Intelligence

The report demonstrates how Jiro's Practice Intelligence platform can translate a complex federal payment proposal into measurable implications for specific specialties and practice settings.

The public report provides national and specialty-level findings. Physician practices can also request a confidential analysis to better understand their potential exposure based on practice type, specialty and claims patterns. Jiro will not publicly identify individual practices included in the analysis.

"Estimating the impact before it reaches the bottom line helps practice owners plan for staffing, services and investment," said Eric Mann, MD, an ophthalmologist, small-practice owner and Jiro Clinical Advisory Board member. "But the implications extend to patient flow and care. If an ophthalmologist finds a foreign body during an exam, for example, the patient should not have to return another day because treating it immediately changes how the visit is paid."

Practice leaders can download the full report and request a confidential practice-level analysis at jirohealth.com/modifier-25-analysis. 

Methodology

Jiro analyzed de-identified Medicare fee-for-service claims covering October 2024 through September 2025. The analysis applied the payment methodology described in CMS's proposed 2027 Physician Fee Schedule to affected same-day services across 67,018 billing NPIs.

The model identifies $888,966,052 in annual modeled reductions that would be redistributed across the Physician Fee Schedule. Specialty classifications were based primarily on the specialty of the rendering clinician associated with affected claims, with directory information used when claims-level specialty data was unavailable.

Practice-setting classifications were developed using multiple affiliation, enrollment and directory sources. For purposes of the topline analysis, private-practice settings include confirmed private practices, practices without an identified hospital or health-system affiliation, private-practice settings identified through affiliation data and solo physicians billing under individual NPIs. These classifications indicate likely practice setting and are not legal determinations of ownership.

Additional information about the methodology and limitations is available in the full report.

About Jiro Health

Jiro is a public benefit corporation building practice intelligence for clinicians and their practices. Its mission is to improve the quality and accessibility of clinical care and research in the United States by returning real-world data to the clinicians who create it. The platform works at three levels: insight for individual clinicians, analytics for the practices they run, and real-world research studies once limited to large institutions. Getting started takes only an NPI, and Jiro is free for verified individual clinicians. Learn more at www.jirohealth.com.

Correction: The links to the report have been updated.

SOURCE Jiro Health