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.
