ISMA signed a Federation letter urging Mehmet C. Oz, MD, Administrator for Centers for Medicare & Medicaid Services (CMS) and Department of Health and Human Services not to finalize the proposed policy to reduce payment by 50% when a separately identifiable office/outpatient (O/O) evaluation and management (E/M) service is reported with the modifier. CMS advances this policy on an unsubstantiated assumption of “likely” duplication, without the evidence a change of this magnitude requires, and without addressing the concerns that led the Agency to decline a substantially similar proposal in 2019. ISMA believes the unintended consequence of CMS’ proposed policy will make it extremely difficult for those independent physician practices to remain viable.