Jiro Practice Impact Analysis · September 2026
Who Pays for CMS’s Modifier 25 Proposal?
A claims-based analysis of the nearly $1 billion payment impact across practice settings and specialties.
$889M
in annual Medicare fee-for-service payments modeled as reallocated
At a glance
The impact would not be distributed evenly.
Jiro modeled the proposal against one year of Medicare fee-for-service claims. Private practices and solo physicians account for most of the modeled reductions, with the impact concentrated in a small number of specialties.
$889M
Annual Medicare fee-for-service payments modeled as reallocated
$724.4M
Modeled reductions tied to private practices and solo physicians
$395.4M
Modeled impact attributed to dermatology alone
What CMS proposed
One encounter. A different payment calculation.
When a Modifier 25 E/M visit and a qualifying global-period procedure occur on the same day, CMS would pay the highest-valued service in full and reduce each other qualifying service by 50%.
Highest-valued service
100%
Each other qualifying service
50%
Where the reductions concentrate
Private practices and six specialties carry most of the exposure.
Modeled reductions by practice setting
Aggregate modeled reduction by specialty
Practice-level variation
Specialty averages do not tell the whole story.
The distance between the median and 90th percentile shows how differently organizations within the same specialty could experience the proposal.
1,795 higher-volume organizations account for 55% of the modeled national total.
This is where Jiro’s analytical capability becomes most tangible: moving from national policy to the practice-level patterns driving exposure.
What happens next
The analysis will be updated when CMS publishes the final rule.
September 14
Public comment period closed
10,000+ comments
Referenced Modifier 25
By November 1
Final rule expected
January 1, 2027
Any finalized policy takes effect
Private impact briefing
What could the Modifier 25 proposal mean for your practice?
National and specialty findings provide context. Procedure mix, Medicare volume and same-day service patterns determine an individual organization’s potential exposure.