On November 1st of this year, the Centers for Medicare & Medicaid Services (CMS) unveiled its final rule for the 2025 Medicare Physician Fee Schedule (MPFS).
As with every final rule, this announcement from CMS will have a profound impact on the healthcare industry. In this piece, we’re going to cover some of the most important pieces of this final rule, as well as what changes in the industry can be expected in the new year.
To begin, let’s discuss the Conversion Factor (CF). For context, until the end of this year, the adjusted 2024 CF is $33.2875. This was a slight increase from the beginning of the year, when the CF was $32.7442; it was later increased in March 2024 as a result of H.R. 4366, which was a minibus package that was part of the Consolidated Appropriations Act, 2024.
Seeing that Congress acted to increase the CF, one might think that the final rule would maintain or increase last year’s number. Instead, the final rule states that the CF for 2025 has been set at $32.3465, representing a 2.83% reduction.
This reduction continues an unfortunate trend of declining Medicare reimbursement rates, creating financial challenges for healthcare providers.
However, similar to how Congress stepped in to adjust the CF earlier this year, there is a strong chance that they could do it again. On October 29th, the Medicare Patient Access and Practice Stabilization Act of 2024 (HR 10073) was introduced by members of the committees of jurisdiction in the House of Representatives.
This bill has bipartisan co-sponsors and, if it is passed, will eliminate the -2.8% Medicare conversion factor (CF) cut and add a +1.8% increase to the CF for 2025.
Another part of the final rule that could require Congressional intervention involves changes made to care involving telehealth.
CMS has extended several telehealth regulatory waivers through 2025, including: allowing providers to use practice addresses instead of home addresses for telehealth services, enabling Federally Qualified Healthcare Centers and Rural Health Clinics to bill for telehealth, and permitting virtual supervision of residents in teaching settings.
However, it should be noted that, absent Congressional intervention, pre-pandemic Medicare telehealth restrictions will return on January 1st.
Alongside these changes came the introduction of six new optional MIPS Value Pathways for reporting starting in 2025 under the Quality Payment Program. For the Medicare Shared Savings Program, CMS finalized policies to address unusual or suspicious billing activity, excluding such payments from financial calculations and historical benchmarks for CY 2024 and beyond.
There’s much to go through with this final rule — and much to be concerned about. While Congress has acted in the past to resolve the shortcomings of previous rules from CMS, it is discouraging that Congressional approval continues to be required, and that the changes that Congress implements are only effective until the next final rule.
This puts physicians in a precarious situation, where they are spending their winters unsure of whether the CF will change in the new year, or if it does, how dramatically.
As the final rule is implemented, and portions of it are potentially updated to reflect the needs of physicians, we will follow the industry’s reactions and keep you up to date.
Recent Comments