TMS and ECT days with a 99214 could lose $66.34: count yours
Medicare's 2027 proposal would halve the lower-paying of the treatment and the 99214. Document what made each visit separate, and keep visits on the days patients need them.
Co-founder, JotPsych
Your Medicare patient gets transcranial magnetic stimulation (TMS), and you bill a 99214 with modifier 25 the same day. Medicare's 2027 proposal would halve the lower-paying of the TMS and the 99214. Count your TMS days with a 99214.
Your electroconvulsive therapy (ECT) days would get the same proposed cut, and the proposal's national rate for an office 99214 is $132.68. You'd lose at most half of the 99214's rate.
Half of the $132.68 national rate for an office 99214, from Addendum B to the 2027 proposed rule. Your Medicare contractor sets the TMS rate, so the cut on your TMS day could be smaller.
What to do before the final rule
- Count the treatment days that had a visit. Look back one year. Multiply your Medicare TMS and ECT days with a 99214 by $66.34. The result is the most the proposed cut would take, at the national rate.
- Write down what made each visit separate. Medicare pays your visit on a procedure day only when it's "significant and separately identifiable from the procedure," the proposed rule says. Name what the visit addressed in your note. One example is a medication change.
- Keep each visit on the day your patient needs it. Medicare wrote that it does "not find it appropriate to schedule medical services for patients to maximize payment." The proposed rule lists tools Medicare could use to watch for scheduling that maximizes payment: claims editing, comparative billing reports, and medical review.
What the proposed cut would reach
The proposed cut would apply when you bill an office visit with modifier 25 on a procedure day. The procedure would have to carry a 0-, 10-, or 90-day global period: the number of days of related care that its payment covers. The proposed rule counts services by you or by any physician in your group.
| Service | Codes | Global period | Proposed modifier 25 cut |
|---|---|---|---|
| TMS treatment | 90867, 90868, 90869 | 0 days | Applies |
| ECT treatment | 90870 | 0 days | Applies |
| Injection | 96372 | None | Does not apply |
| Spravato session | G2082, G2083 | None | Does not apply |
| Psychotherapy add-on | 90833, 90836, 90838 | Add-on code | Does not apply |
Global periods from Addendum B to Medicare's proposed 2027 fee schedule, updated July 21, 2026. The proposed cut would reach a service only when it carries a 0-, 10-, or 90-day global period.
Your injections and Spravato sessions carry no global period, and your psychotherapy add-ons, such as 90833, are add-on codes, so the proposed cut would skip all three. Your 99214 billed alone or with a 90833 would keep full payment.
Medicare can still change the proposal in the final rule. Medicare asked for comments on whether the proposed cut should use another value, such as 25 percent instead of 50, and whether it should also reach inpatient visits.
"We've been pushing back," said Anders Gilberg, senior vice president of government affairs at the Medical Group Management Association. "We've been meeting with the White House."
Dates from the proposed rule (Federal Register, July 16, 2026) and federal law, which requires the final fee schedule before November 1. The final rule can change the proposed cut's size and reach, so redo your count when the final rule publishes.
The final rule is due before November 1. Read the final rule for any cut's size and reach. Then redo your count.
JotAudit checks each note before you sign, against rules your practice writes, like naming what the visit addressed.
See JotAudit- Anders Gilberg, senior vice president of government affairs, Medical Group Management Association (MGMA), “CEO Summit: Education”, MGMA 2026 Annual Conference, San Antonio, September 27, 2026.
- Centers for Medicare and Medicaid Services (CMS), 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), Federal Register document 2026-14327, July 16, 2026: the modifier 25 proposal at 91 FR 43907 to 43909, the conversion factor at 91 FR 44241.
- CMS, Addendum B to the 2027 proposed rule: relative value units and global periods, updated July 21, 2026.
- United States Code, title 42, section 1395w-4(b)(1), the deadline for the annual fee schedule, via the Legal Information Institute, Cornell Law School.