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 the Medicare program for 2025, including several proposals which show the positive impact of your Academy’s advocacy efforts throughout the year. Key elements of this proposed rule are described below, including numerous areas impacting PM&R. Your Academy is continuing to review the rule and will update our website with proposed changes to relative value unit (RVU) values and payment for PM&R services, in the coming weeks.

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 and a positive budget neutrality adjustment of 0.05% due to proposed 2025 policies.

Medicare physician payment reform continues to be one of your Academy’s primary advocacy priorities. Our Academy Future Leaders met with legislative offices on Capitol Hill in June this year, encouraging congressional action on payment reform. These meetings followed advocacy efforts earlier in April by the Academy’s Health Policy and Legislation Committee, where committee members met with congressional committees of jurisdiction on this topic. Additionally, your Academy submitted comments to the Senate Finance Committee recommending positive annual increases to physician payment commensurate with inflation.

Your Academy continues to advocate on this issue, but it’s time to make sure your voice is heard by Congress on this issue. Take less than five minutes today to contact your representatives iin the U.S. Congress and urge them to take immediate action to implement a fair and sustainable long-term fix to the Medicare physician payment system. Visit this page and click on the second campaign, “Fix Medicare Now!” to send your message. While you’re there, check out our other active campaigns and help us by sending a message related to prior authorization and scope of practice.

Telehealth

Your Academy continues to closely monitor Medicare policy related to coverage for telehealth services, particularly since the COVID-19 pandemic. In the proposed rule, CMS highlights that many of the expansions of telehealth coverage currently in place 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. These flexibilities have allowed coverage of telehealth services provided from the patient’s home and for all patients, regardless of where they reside in a healthcare professional shortage area. Your Academy has been advocating for these flexibilities, along with payment parity, to be made permanent following the pandemic.

CMS is also proposing to expand their definition of “interactive telecommunications system” to include two-way, real-time, audio-only communication technology. Audio-only services have previously been excluded from CMS’s definition of telehealth. This is a change your Academy has historically advocated in support of, recognizing that many PM&R patients may struggle with audio/video telehealth.

In February 2023, the American Medical Association Current Procedural Terminology (AMA CPT) Editorial Panel finalized new codes describing telemedicine services that describe outpatient evaluation and management (E/M) audio/video and audio-only telemedicine services. Academy staff anticipated this series of codes could be implemented for Medicare coverage effective January 1, 2025. However, CMS has stated in the proposed rule that it does not believe “there is a programmatic need to recognize the audio/video and audio-only telemedicine E/M codes for payment under Medicare.” CMS will continue to pay for telehealth E/M services using the existing office/outpatient E/M codes with the appropriate place of service code and modifier. Your Academy is supportive of this strategy as it ensures telehealth services are reimbursed at parity with in-person services, which is an Academy advocacy priority.

G2211 – Evaluation and Management (E/M) Visits)

In the proposed rule, CMS describes minor changes to coverage restrictions for the G2211 complexity add-on code. CMS has proposed allowing G2211 to be billed on the same day and by the same practitioner as an annual wellness visit, vaccine administration, or any Medicare Part B preventive service provided in the office or outpatient setting. No other changes are proposed for G2211, which some Academy members have had success billing to capture longitudinal patient care.

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 and how we are advocating for changes to MIPS on the Academy website.

MVPs

CMS proposes expansion of its MIPS Value Pathways (MVPs) 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.

A fact sheet about the rule is available on the CMS website. Additionally, CMS has released a fact sheet specific to the Quality Payment Program. If you have specific questions about the proposed rule, please email healthpolicy@aapmr.org.