To the Editor:
I am writing about the May 2026 coding column—not to relitigate its technical claims, but to raise a structural concern that I believe is more important than any single interpretation: The column was published without any disclosure of the author’s financial relationships in the very procedural categories it discusses.
Medicine has spent 2 decades building disclosure norms around clinical influence. The Sunshine Act tracks a physician who accepts a sandwich from a manufacturer. Yet an entire ecosystem of reimbursement intermediaries operates outside that scrutiny—and these are not peripheral actors. The same consultant may simultaneously advise manufacturers on reimbursement strategy, author sponsored coding materials, consult for physician practices, shape how codes are interpreted across the specialty, and then publish instructional guidance in a journal like yours. Each role informs the others. None of it is disclosed.
That asymmetry is no longer defensible. Coding guidance is not neutral plumbing. It shapes physician billing behavior, technology adoption, referral patterns, and ultimately patient access. When that guidance steers surgeons away from certain settings or pathways, the downstream effect—particularly for elderly glaucoma patients already facing barriers to care—is delayed treatment and preventable progression of sight-threatening disease. Coding influences economics, and economics influences access. That is precisely why undisclosed reimbursement influence deserves the same scrutiny medicine now applies to undisclosed clinical influence.
I examined this problem at length in a recent op-ed, “Where There Is No Sunshine [Act]: How Unregulated Reimbursement Consultants Troll in the Shadows of Healthcare.” The piece traces how reimbursement consulting has become a quiet but powerful lever over clinical practice—one that operates with none of the transparency now demanded of physician-industry relationships. These intermediaries shape coding interpretation, author the materials physicians rely on, and consult for the manufacturers whose technologies those codes govern, all while remaining invisible to the disclosure regimes that bind everyone else at the table. The May 2026 column is a near-textbook illustration of exactly the dynamic I described: the same conflicts, converging on the same author, advanced without a word of disclosure.
A specialty journal has an obligation to apply its disclosure standards to coding instruction as rigorously as it does to clinical content. If a reimbursement consultant’s published guidance overlaps with their commercial consulting interests, readers are entitled to know. A journal should not function as an unexamined distribution channel for commercially entangled parties promoting their own services. If it chooses to publish such material, the relationships should be disclosed prominently—and if they cannot be, that material should be treated, and charged, as advertising.
I would ask the journal to require full disclosures on this column going forward, and to publish this letter alongside it. I raise this with real respect for your editorial team and for Dr. Radcliffe, a colleague and friend whose standards I trust would not permit this to pass unnoticed.
On the substantive reimbursement question, my view is straightforward: We should embrace innovation that brings real clinical utility, including when it breathes new life into dormant codes. Many “zombie” codes have lapsed into disuse and sit languishing, of value to no one, not patients, not physicians. When innovation reanimates such a code and allows doctors to deliver a new treatment under it, that is a feature, not a violation. It is precisely how a coding system should adapt to clinical progress.
The CPT code proliferation is already drowning clinical practice. We carry more than 11,000 CPT codes, a sprawl that chiefly profits the AMA and the reimbursement consultants who interpret it, not the doctors and patients it is supposed to serve. Coding should follow the clinical science and reflect the procedures physicians actually perform. We should not fall captive to bureaucrats and coding clerks who have no familiarity with the clinical science and surgical paradigm of ophthalmology, and whose interpretations—however confidently asserted—raise barriers for patients seeking care and physicians trying to practice good medicine. No one but the AMA which collects royalty on every CPT code every year (to the tune of billions!) and the reimbursement billing consultants who thrive on coding complexity (neither of whom actually contribute to patient care) want more codes. We need excellence in clinical care, not CPT code proliferation!
—Tsontcho (Sean) Ianchulev, MD, MPH
Author's Response
I appreciate the opportunity to respond to Dr. Ianchulev’s letter regarding my article on coding and billing as it related to the AlloFlo Uveo (Iantrek) procedure.
Reasonable physicians may differ regarding the clinical promise of new surgical technologies. My article, however, was not a commentary on the merits of the procedure, nor did it suggest that surgeons should or should not perform it. Its purpose was much narrower: to explain how the procedure should be reported on a claim for reimbursement under the current CPT system. That distinction is important.
The central issue addressed in the article was a specific coding question that was submitted to the American Medical Association’s CPT Assistant in late 2024, around the time that this new procedure was introduced. The response concluded that neither CPT code 66740 nor CPT code 67255 appropriately describes the procedure and that, until a specific CPT code(s) exists, an unlisted ophthalmic procedure code is the appropriate method of reporting the service. My article simply presented that guidance and advised readers to follow it.
Dr. Ianchulev’s letter does not identify an error in the CPT Assistant’s analysis. Instead, he offers reasons why he believes existing coding conventions should not impede adoption of an innovative procedure. That is an important policy discussion, but it is different from the practical question physicians face today when submitting claims for payment. Fortunately, the coding issue is already being resolved through the CPT process. In February 2026, the CPT Editorial Panel approved an application for a new Category III code for this procedure, recognizing that an existing CPT code does not adequately describe the service now or previously. Once this code becomes effective January 1, 2027, physicians will have procedure-specific reporting guidance.
Innovation in glaucoma surgery deserves thoughtful evaluation and fair consideration. Equally important is adherence to established coding guidance until that guidance changes. The CPT process has a mechanism to address new technologies, which Dr. Ianchulev used in 2026. My article was intended to help physicians comply with the current CPT framework and the associated Medicare regulations for unlisted codes. When an authoritative coding source and a manufacturer’s reimbursement recommendations differ, physicians are best served by following the authoritative coding guidance.
Kevin J. Corcoran
Principal, Corcoran & Corcoran