On July 10, 2024, the Centers for Medicare & Medicaid Services (CMS) published the annual Medicare Physician Fee Schedule (MPFS) proposed rule. The rule describes proposed payment, policy, and quality program changes for 2025, including several proposals which show the impact of AAPM&R advocacy efforts throughout the year. AAPM&R submitted comprehensive comments to CMS regarding the proposed rule on September 9.
Updates to Physician Payment
Of immediate concern, the rule includes a proposed 2.8% reduction to the Conversion Factor, which is used to calculate payment for all services paid under the MPFS. This decrease is due to the expiration of the 2.93% increase provided by Congress for 2024 as well as a positive budget neutrality adjustment of 0.05% due to proposed 2025 policies. Download our AAPM&R payment comparison chart to see the potential impact of the conversion factor cut on payment for physiatry services in 2025.
Telehealth
The Academy has been closely monitoring Medicare policy related to coverage for telehealth services, particularly since the COVID-19 pandemic. In the proposed rule, CMS highlights that many of the currently in place expansions of telehealth coverage will expire at the end of 2024 without Congressional intervention. This includes the flexibility to provide telehealth without geographic restriction and without limit on the patient’s originating site. This has resulted in coverage of telehealth services provided from the patient’s home and for patients who do not reside in a healthcare professional shortage area. AAPM&R has been advocating for these flexibilities, along with payment parity, to be made permanent following the pandemic.
Quality Payment Program
MIPS
For the 2025 performance period, CMS is proposing to maintain the current weights for the Merit-based Incentive Payment System (MIPS) performance categories. Quality: 30%; Cost: 30%; Improvement Activities: 15%; and Promoting Interoperability: 25%. Further, CMS has proposed maintaining the performance threshold at 75. CMS proposes several changes to the individual categories, including adding new cost measures and updating methodologies for certain quality measures. Learn more about MIPS reporting for PM&R on the Academy website.
MVPs
CMS proposes expansion of its MIPS Value Pathways program to include six new MVPs as well as modifications to existing MVPs. Learn more about MVPs, including the Rehabilitative Support for Musculoskeletal Care MVP, on the Academy website.
Alternative Payment Models - Request for Information on Value-Based Care
In the proposed rule, CMS seeks input on the design of a potential model aimed at engaging specialists in value-based care. Your Academy is reviewing this request for information and will consider developing comments informed by our AAPM&R Principles of Alternative Payment Models, which were developed in 2022 by our Innovative Payment and Practice Models Committee.
Comments regarding the rule are due to CMS by September 9, 2024, and can be submitted via the Federal Register website once the rule has been officially posted. Your Academy will submit comments on the above-described issues and other elements of the rule on behalf of physiatry. #PMRAdvocates are also encouraged to submit their own comments to CMS.
Effective January 1, 2024 the Centers for Medicare and Medicaid Services implemented payment for G2211, a HCPCS add-on code to be billed in conjunction with an office/outpatient evaluation and management (E/M) code in certain instances. Learn more about how to use this resource and applications for physiatry.
On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) released the calendar year 2024 Medicare Physician Fee Schedule. Policies described in the rule will go into effect on January 1, 2024. AAPM&R submitted detailed comments to CMS regarding their proposed rule in September.
The rule finalized a 3.37% reduction to the Conversion Factor, decreasing from the 2023 rate of $33.89 to $32.74. On March 8, following extensive AAPM&R advocacy, Congress passed a partial government funding package which included an update to the conversion factor. The conversion factor for the remainder of 2024, effective March 9, is $33.29. Download our updated AAPM&R payment comparison chart to see 2024 payment rates for physiatry services effective March 9.
AAPM&R has successfully advocated on several policies finalized in the 2024 rule:
We are reviewing the rule in further detail and will be preparing additional summary information for members including specific information about payment rates for physiatry services. The rule includes new policies related to telehealth, new coding opportunities for E/M visits with complex patients and for caregiver training services, as well as updates to several important quality programs.
See the Academy's advocacy efforts for this final rule:
On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) published the annual Medicare Physician Fee Schedule (MPFS) proposed rule. The rule describes proposed payment, policy, and quality program changes for 2023, including several proposals which may impact physiatry. On September 11, 2023, AAPM&R submitted comments to CMS regarding the proposed rule on behalf of physiatry. Additionally, 142 Academy members submitted letters to CMS as a part of the Academy’s grassroots letter writing campaign.
Medicare payment for physicians, and some non-physician practitioners (NPPs), is based on set rates under Medicare Part B. The system for payment, known as the Medicare Physician Fee Schedule (MPFS), is used when paying for: professional services of physicians and some NPPs; covered services incident to physicians’ services (other than certain drugs covered as incident to services); diagnostic tests (other than clinical laboratory tests); and radiology services. The MPFS also addresses various quality issues, fraud and abuse issues, and other issues that impact physicians. CMS updates the MPFS regulations annually, with comment periods open prior to implementation of the final rule.