CMS Issues CY2025 Physician Fee Schedule Proposed Rule

Yesterday, the Centers for Medicare & Medicaid Services (CMS) released the 2025 Medicare Physician Fee Schedule (PFS) proposed rule. Your ACOI team will analyze the proposed rule to identify policies that could impact osteopathic internists, their practices and patients.

CMS’ proposed conversion factor for CY2025 is $32.3562, which takes into account the statutorily required update to the conversion factor for CY 2025 of 0% and removal of the temporary 2.93% payment increase provided by Congress for services furnished from March 9, 2024, through Dec. 31, 2024.

The proposed conversion factor—a key element for determining physician payment under the Medicare PFS—represents a 2.8% percent decrease from the CY2024 PFS conversion factor of $33.2875.

Preventing a payment cut will require intervention by Congress before the end of this year. In June, ACOI sent a letter to congressional lawmakers asking for an annual inflation-based payment update based on the Medicare Economic Index, which is projected to be 3.6% in 2025. When adjusted for inflation in medical practice costs, Medicare physician pay has declined 29% since 2001.

Other Highlights from the Rule:

• Most of the COVID-era telehealth flexibilities will end Dec. 31, 2024 without action from Congress. CMS does propose, however, to continue its current policy to allow teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in all teaching settings through Dec. 31, 2025.
• CMS proposes to establish coding and make payment under the PFS for a new set of advanced primary care management (APCM) services. The proposed APCM services would incorporate elements of several existing care management and communication technology-based services into a bundle that reflects the essential elements of the delivery of advanced primary care, including principal care management, transitional care management, and chronic care management. Starting Jan. 1, 2025, physicians and non-physician practitioners who use an advanced primary care model of care delivery could bill for APCM services when they are the continuing focal point for all needed health care services and responsible for all the patient's primary care. Billing the APCM codes would be contingent upon a quality reporting requirement.
  
  CMS proposes to expand coverage of hepatitis B vaccinations for individuals who have not previously received a completed hepatitis B vaccination series or whose vaccination history is unknown.  
  
  For CY2025, CMS is proposing to allow payment of the office/outpatient (O/O) evaluation and management (E/M) visit complexity add-on code G2211 when the O/O E/M base code is reported by the same practitioner 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.

ACOI will develop comments in response to these and other proposals in the rule. Please refer to the following documents for more information:

• CMS CY2025 Medicare Physician Fee Schedule Proposed Rule Fact Sheet
• CMS CY2025 Medicare Physician Fee Schedule Proposed Rule