On July 10, 2024, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2025 Revisions to Payment Policies Under the Physician Fee Schedule (PFS) and Other Revisions to Medicare Part B [CMS-1807-P] Proposed Rule, which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). Physicians and other clinicians are once again facing large proposed cuts of 2.8% for CY 2025. Ultimately, the rule outlines the limitations of the current fee schedule structure, and while Congress has provided temporary partial fixes to physician payment in the last several years, the relief expires at the end of 2024 unless legislation is passed.
Beyond the proposed payment cuts, CMS proposes significant policies related to telemedicine, changes to the Merit-Based Incentive Payment System (MIPS) cost and improvement activity scoring, movement towards the MIPS Value Pathways (MVPs) and several other important polices.
Key takeaways from the CY 2025 PFS Proposed Rule:
- Conversion Factor (CF) Reduction: CMS proposes a 2025 CF of $32.3562, representing a 2.8% reduction from the 2024 physician CF of $33.2875, and a 2025 anesthesia CF of $20.3340, representing a 2.1% reduction from the 2024 anesthesia CF of $20.7739.
- Add-on Code for Complexity: CMS proposes to expand the useability of the add-on code for complexity, G2211, by allowing it to be billed when the underlying evaluation and management (E/M) service is performed on the same day as an annual wellness visit, vaccine administration, or any Medicare Part B preventive service furnished in the office or outpatient setting.
- Telehealth: CMS maintains it has limited statutory authority to extend most Medicare telehealth policies. Without congressional action, the major Medicare telehealth waivers will expire on December 31, 2024, and return to pre-COVID-19-public-health-emergency (PHE) policies.
- Merit-Based Incentive Payment System (MIPS): CMS would maintain the MIPS performance threshold at 75 points but signals efforts to move reporting towards the MIPS Value Pathways (MVPs) by 2029.
- Medicare Shared Savings Program (MSSP): CMS proposes to establish a new prepaid shared savings option, modify the financial methodology to encourage participation, align quality measure reporting with the Universal Foundation of quality measures, and account for the impact of certain improper payments in performance year and benchmark expenditures.
Comments on the proposed rule are due on September 9, 2024.
This content is for McDermott+ clients only; please contact your relationship consultant with questions. For inquiries, please contact info@mcdermottplus.com.
McDermott+ has developed an interactive dashboard that shows proposed Medicare fee-for-service payment rates for 2025 at the national and local level for services paid under the Medicare PFS. You can use this information to look at trends in national payment rates over the last five years and identify how service level payments differ across localities.
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Emily Curran, associate at McDermott Will & Emery, also contributed to this +Insight.
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