Read the full analysis
AskthedatawhopaysforModifier 25.
One year of Medicare claims, modeled against CMS's CY 2027 proposal. The proposal is not final.
$889M
Annual Medicare payments at risk
23.1M
Affected patient-days
67,018
Billing NPIs affected
80%
Borne by private practices
Where the $889M falls
Six specialties, modeled annual exposure
Dermatology44.5% of total$395.4M
Podiatry9.6% of total$85.7M
Orthopedic surgery9.3% of total$83M
Otolaryngology9.2% of total$82.2M
Ophthalmology5.2% of total$46.2M
Family medicine4.4% of total$39.1M
Who absorbs it
Share of impact by practice setting
- 81.5%
Private / solo · $724.4M - 17.6%
Hospital-affiliated - 0.9% Other
Same specialty, very different outcomes
Median to 90th percentile, higher-volume organizations
Dermatology$45K – $214K
Otolaryngology$28K – $135K
Orthopedics$21K – $129K
Ophthalmology$21K – $105K
What's next
The rule is proposed, not final
- Sept 14, 2026Comment period closed · 10,000+ comments
- By Nov 1, 2026Final rule expected
- Jan 1, 2027Changes would take effect