Important CMS Proposal Impacting Dermatology Practices | SDNP

Important CMS Proposal Impacting Dermatology Practices

  • August 20, 2026
The Society of Dermatology Nurse Practitioners (SDNP) is bringing your attention to an important proposed rule from the Centers for Medicare & Medicaid Services (CMS) that could have a significant impact on dermatology practices and the patients we serve.

CMS has proposed changes to reimbursement for Modifier 25, which is used when a patient requires a significant, separately identifiable evaluation and management (E/M) service on the same day as a minor procedure. In dermatology, this is a common and medically appropriate part of patient care.

Examples include:

  • Evaluating a suspicious lesion before performing a biopsy.
  • Treating actinic keratoses while also managing chronic conditions such as eczema or psoriasis.
  • Assessing a new skin concern during a visit that also requires a medically necessary procedure.

If finalized, this proposal could have far-reaching consequences for dermatology practices and Medicare beneficiaries by:

  • Reducing reimbursement for appropriately documented E/M services.
  • Increasing the need for additional patient visits.
  • Delaying diagnosis and treatment, including the early detection of skin cancer.
  • Increasing costs and inconvenience for patients.
  • Adding unnecessary administrative and financial burdens to dermatology practices.

CMS Proposed Rule – https://www.cms.gov/medicare/payment/fee-schedules/physician

CMS Fact Sheet – https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule

Submit a Comment to CMS – https://www.regulations.gov/document/CMS-2026-2377-0002

Sample Comment Letter –  https://acrobat.adobe.com/id/urn:aaid:sc:US:31914239-1b10-4be8-8949-a5acad16ee51