CMS Issues CY 2025 Proposed Rules for Medicare Physician Fee Schedule (MPFS)

On July 10, 2024, the Centers for Medicare and Medicaid Services (CMS) issued the proposed rule for the Medicare Physician Fee Schedule (MFPS) for calendar year (CY) 2025. These proposed rules cover physician services furnished to beneficiaries on or after January 1, 2025. Highlights are described below:

CMS proposed Conversion Factor (CF) of $32.3562, which includes a budget neutrality factor of 0.05 percent, and a statutory update factor of 0.00 percent.
Based on the proposed changes for the RVUs, CMS estimates combined payment impact for cardiac surgery at 0 percent; for cardiology at 0 percent; interventional radiology at -2 percent; and for vascular surgery at -2 percent.
Proposals for the geographic practice cost indices (GPCIs) include continuation of work floor GPCI at 1.000; and continuation of Alaska work floor GPCI at 1.500 and frontier states at 1.000. The next proposed GPCI update is expected for CY 2026.
The Medicare Economic Index (MEI) cost share weights are based on data collected by the AM for self-employed physicians from the Physician Practice Information Survey (PPIS). A current survey is underway and expected to be completed by the end of CY 2024. Therefore, CMS once again proposed to delay the implementation of the 2017-based MEI ratesetting for CY 2025.
CMS addressed five potential misvalued codes and multiple proposed value changes to specific new and established CPT® codes.

CMS proposed changes to their current policy by allowing payment of the office/outpatient (O/O) E/M visit complexity add-on payment (code G2211) when this service is reported by the same provider on the same day as Annual Wellness Visit (AWV), vaccine administration or any Medicare Part B preventive service furnished in the office or outpatient setting.
In CY 2024, CMS finalized the proposal to combine the Category 1-3 classifications into a 5-step process for determining additions and deletions to the Medicare Telehealth Services List. This process involves categorizing each service as “permanent” or “provisional” status. CMS evaluated multiple services for potential addition or deletion to the Medicare Telehealth Services List using this process for CY 2025.
CMS proposed to continue payment for telehealth services to the originating site facility fees. The proposed MEI for CY 2025 is 3.6 percent, resulting in a proposed originating site fee of $31.04 for HCPCS code Q3014 (Telehealth originating site facility fee).
For CY 2025, The CPT® Editorial Panel added a new E/M subsection to the draft CPT® codebook for Telemedicine services. In addition, the Panel added 17 codes for reporting telemedicine E/M services. With the addition of these new telehealth codes, the AMA CPT® Editorial Panel has deleted the current audio-only CPT® codes 99441-99443. CMS does have them listed on the telehealth list as “provisional” through December 31, 2024.
CMS is proposing to temporarily extend the definition of direct supervision and “immediate availability” of the supervising practitioner to include the use of real-time audio and visual interactive telecommunications (excluding audio-only) through December 31, 2025.
CMS proposed to continue to allow teaching physicians to have a virtual presence in all teaching settings, but only in clinical instances when the service is provided virtually (3-way telehealth visit, with all parties in separate locations).
CMS proposed to revise the transfer of care policy for global packages to address instances where one practitioner furnishes the surgical procedure and another practitioner furnishes related post-operative E/M visits during the global period; and develop a new add-on code that would account for resources involved in postoperative care provided by a practitioner who did not furnish the surgical procedure.

The complete MPFS proposed rule summary can be found on the GORE Coding Resource Center website under “Education – CMS Rules Updates”: https://gore.rccsclients.com/education/rules-updates/.