The CY 2025 Medicare Physician Fee Schedule and Quality Payment Program proposed rule was released earlier this week.
AAFP has issued a statement.
As the Practice Advancement and Government Relations teams continue to
digest the 2,248-page rule in the coming days, more updates will come as
to what this means for family medicine.
Here are a few high-level takeaways:
- The proposed conversion factor for CY 2025 is $32.3562 which is a 2.8% reduction
as compared to the 2024 conversion factor. This is due to expiring
conversion factor relief enacted by Congress as well as budget
neutrality adjustments.
- When taking into account expiring conversion factor relief, we estimate that the impact will be a 1.9% decrease in total allowed charges for family physicians.
- Please note that the specialty impact table in the proposed rule
estimates that family medicine will experience a 1% increase in total
allowed charges, but this number does not take into account the expiring
2.9% CF relief because it occurs outside of budget neutrality.
- CMS accepted our request to allow payment for G2211 even when
modifier 25 is appended to the accompanying office/outpatient evaluation
and management (E/M) in certain instances. Beginning in 2025, on claims
where modifier 25 is used to facilitate reporting a Medicare Annual
Wellness Visit (AWV), vaccine administration, or Medicare Part B
preventive services at the same encounter as the E/M service G2211 can
also be paid.
- CMS also proposes new bundled payments for advanced primary care
teams. CMS is creating three new HCPCS codes for APCM services that
incorporate elements of several existing care management and
communication technology-based services into a bundle. Practices must
meet several requirements before billing the codes, but CMS notes this
is a first step in a multiyear effort towards hybrid payment and
accountable care. CMS has released an RFI to gather feedback on
potential payment policies for advanced primary care services, and the
team will do a full review of the details of this proposal.
- Beginning in 2026, CMS proposes to establish advanced payments for
ACOs to enable investments in infrastructure or staffing to improve care
coordination and quality. The new “prepaid shared savings” option would
be available to ACOs with a history of earning shared savings in BASIC
Tracks C-E and the ENHANCED track.
- CMS is proposing to allow two-way, real-time audio-only for any
telehealth service furnished to a beneficiary in their home when the
patient is not capable of or does not consent to use of video
technology. However, once the PHE-related telehealth flexibilities
expire on December 31, 2024, the patient’s home is only a permissible
originating site for services for the diagnosis, evaluation, or
treatment of a mental health or substance use disorder, and for monthly
ESRD-related clinical assessments.
- CMS proposes a new code for an annual cardiovascular risk assessment
administered on the same day as an E/M visit, based on a risk-reduction
model tested during the CMS Innovation Center’s Million Hearts
Cardiovascular Disease (CVD) Risk Reduction model.
- CMS also proposes to expand behavioral health services with a new
code for safety planning interventions and post-discharge follow up for
people at high risk of suicide or overdose.
- CMS included a request for information on a potential permanent
expansion of the list of services under the primary care exception, a
change we requested.
The primary care exception allows the teaching physician to bill for
services furnished by residents when certain conditions are met.
Aside from the expected reduction in the conversion factor, most
proposals impacting family practice are the direct results of AAFP
advocacy or are positive developments for the profession.
To learn more about the proposed rule, here are the CMS links posted on Wednesday: press release, MPFS fact sheet and MSSP fact sheet.
