In yet another destabilizing move for physician practices, Medicare on July 10 proposed what amounts to another pay cut for the nation’s physicians in the face of increasing costs, positioning organized medicine for heightened advocacy.
In slight relief, however, the Centers for Medicare & Medicaid Services (CMS) in its release of the 2025 proposed Medicare physician fee schedule followed American Medical Association recommendations to maintain rather than increase the Merit-Based Incentive Payment System (MIPS) performance threshold in light of disruptions caused by the COVID-19 pandemic and Change Healthcare cyberattack. The agency also proposes the continuation of limited telehealth flexibilities.
“TMA remains extremely frustrated that Congress allows these cuts to occur. Lawmakers must act now to provide inflationary updates that reflect the increasing cost of providing medical care,” TMA President G. Ray Callas, MD, said. “We expect the AMA to advocate forcefully to stop this cut. TMA and state medical societies stand ready to work with the AMA to end this cycle of cuts that threaten physician practice viability in our country.”
For the fifth straight year, the 2025 CMS regulation forecasts a reduction in the Medicare conversion factor used to calculate physician payments, which at $32.36 represents a 2.80% payment decrease compared with 2024 (the latter of which applied to services rendered from March 9 through Dec. 31 due to delayed congressional action).
The prospective 2025 cut comes after Congress in 2024 was unable to avert the full 3.37% pay reduction (knocked down to 1.68%); physicians were the only Medicare providers to not receive an inflationary update that year. Congress also allowed the full 2% cut to go through in 2023.
Among several positive developments, CMS proposes to maintain the MIPS performance threshold at 75 points and the 75% data completeness criteria. Other potential MIPS updates include:
- Adding six cost measures;
- No changes to the promoting interoperability category; and
- Continued development of MIPS Value Pathways (MVPs) as a voluntary and optional, for now, alternative quality reporting method for specialists.
If the six newly proposed MVPs (ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care) are finalized, CMS estimates that 80% of specialties would have an applicable MVP in 2025.
In other value-based care developments, CMS proposes to establish a “prepaid shared savings” option for the Medicare Shared Savings Program in performance year 2026. Eligible accountable care organizations would include those that participate in levels C-E of the BASIC track or the ENHANCED track and have a history of earning shared savings. The quarterly payments could be used to invest in staffing, infrastructure, and patient services.
On telehealth, CMS proposes to maintain certain flexibilities such as virtual direct supervision to auxiliary personnel when required. However, absent congressional intervention, on Jan. 1, 2025, the geographic site restriction will revert to pre-COVID-19 public health emergency requirements, meaning only Medicare patients residing in rural areas may access non-behavioral telehealth and must do so through a facility.
The agency also proposes to expand coverage of certain preventive services such as hepatitis B vaccinations, drugs covered as additional preventive services, and colorectal cancer screenings.
As TMA staff along with appropriate TMA boards, councils, and committees review the proposed regulation, they will prepare a comment letter for submission by the Sept. 9 deadline. CMS is expected to post the final rule around Nov. 1, and changes take effect Jan. 1, 2025.
Continue to read Texas Medicine Today for updates. If you have questions or comments for TMA to consider, please email the Knowledge Center.
Additional resources on changes in the 2025 Medicare Physician Fee Schedule (MPFS) proposed rule: