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.