76 Physicians in 24 States Used Nemedic's Free AI Assistant to Draft Their Own Modifier-25 Comments to CMS

WESTFIELD, Ind. — Seventy-six physicians from 24 states signed up for Nemedic's free Modifier-25 Comment Assistant and used it to draft comments to the Centers for Medicare & Medicaid Services before the agency's comment period closed on September 14, 2026.

The comments responded to CMS's proposal, in its proposed 2027 Physician Fee Schedule, to reduce payment for evaluation and management services billed with modifier 25. Physicians add the modifier when a significant, separately identifiable evaluation happens on the same day as a procedure.

Nemedic built the assistant at the request of a North Carolina otolaryngologist who had written his own comment and wanted his colleagues to file theirs. It worked entirely by email. Each physician answered questions about their own practice, from same-day procedure cases to local drive times and appointment waits, and received a draft built from those answers.

The assistant used only facts the physician supplied and did not invent statistics. It drafted the comment, and the physician reviewed, edited and submitted it.

On August 20, Bradford G. Bichey, MD, MPH, founder and chief executive officer of Nemedic, emailed physicians who had used an earlier Nemedic agent to write to Congress about H.R. 6160. Physicians forwarded the link to their partners, Dr. Bichey wrote to colleagues he knew from panels and meetings, and a one-page flyer was faxed to ENT practices in August.

Nemedic has retired the assistant and kept it in place to adapt for future comment periods. CMS will decide whether to adopt the modifier 25 change in its final rule.

An account of how the campaign came together is on the useBlue.ai blog. Nemedic is not affiliated with CMS, and the assistant did not represent the position of any medical society.