Heart of Health Policy | Cuts Continue: CMS Releases Proposed 2025 Medicare Physician Fee Schedule
The Centers for Medicare and Medicaid Services (CMS) released the proposed 2025 Medicare Physician Fee Schedule (PFS) on July 10. Of note, the PFS conversion factor has been updated from $33.2875 to $32.3562, a 2.80% cut. The overall reimbursement for cardiovascular services is projected to remain flat compared with 2024, with changes to policies and individual services roughly balancing out. Individuals and groups will see different impacts depending on patient populations and services offered.
Highlights from the proposed rule include:
- A proposal to unwind geographic location telehealth flexibilities that began during the COVID-19 public health emergency and were extended through 2024 by Congress, as required by current law. Several bills under consideration in Congress would extend or make telehealth flexibilities permanent.
- For 2025 and beyond, CMS proposes to allow two-way, real-time audio-only communication to satisfy the requirement for an interactive telecommunications system, when appropriate.
- A proposal to "broaden the applicability of transfer of care modifiers" for 90-day global services. CMS is seeking to deliver more accurate reimbursement of these global services by breaking down payments to preoperative management, surgical care only, and postoperative management only, and is requesting suggestions from stakeholders on how best to implement this.
- A proposal to maintain cardiac rehabilitation services on the telehealth list provisionally through 2025.
- Updated code values for new/revised services, cyclical updates to the Quality Payment Program (QPP), updates to the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) for 2025, the Medicare Shared Savings Program and other payment policy proposals.
- In continuing to seek out ways to incorporate refreshed data to the fee schedule – such as the ongoing American Medical Association Physician Practice Information Survey – CMS has retained the RAND Corporation to develop other methods for measuring practice expenses and updating payments.
- A request for information on sunsetting traditional MIPS and completing the transition to MVPs for the 2027 reporting year/2029 performance period.
- Information request on a potential ambulatory specialty care model that incorporates MVPs to increase specialist engagement in value-based care and expand incentives for primary and specialty care coordination.
- A newly proposed MVP targeting surgical care, which would encompass procedures provided by cardiothoracic surgeons.
- A proposal to require Shared Savings Program Accountable Care Organizations to report the new Advanced Practice Provider Plus quality measure set and to submit their measures through the electronic care quality measure (CQM) or Medicare CQM collection types.
Look for updated information regarding these proposed rules on ACC.org/Advocacy and in upcoming issues of The Advocate newsletter. The ACC Advocacy team is reviewing these proposals and drafting written comments for submission to CMS and ONC before the comment period ends.
Learn more about the work the ACC Advocacy team does behind the scenes to respond to regulatory proposals and advocate on behalf of ACC members with the ACC's Regulatory Affairs Roadmap. Click here to explore the timeline from proposed rule to final rule.
Key Provisions From Proposed Hospital OPPS, Health IT Rules
The proposed 2025 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System rule was also issued on July 10. CMS proposes a 2.6% increase to OPPS payment rates that reflects a market basket update of 3.0% reduced by a productivity adjustment of 0.4%.
The only cardiovascular changes to the ASC covered procedure list (CPL) are the addition of Category III dual-chamber leadless pacemaker codes, indicating no movement on the addition of ablation to the ASC CPL. There are no cardiovascular changes adding or removing services from the inpatient-only list.
In the Hospital Outpatient Quality Reporting Program, the Cardiac Imaging for Preoperative Risk Assessment for Non-Cardiac, Low-Risk Surgery measure is proposed for removal beginning with the 2025 reporting period/2027 payment determination. CMS states that the measure does not yield sufficiently meaningful data to improve patient outcomes.
In addition, the Office of the National Coordinator for Health Information Technology (ONC) released the Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule, building on the HTI-1 final rule released in 2023 and additional information blocking rules released by CMS and ONC in 2021.
Highlights From HTI-2 include:
- New certification criteria for electronic health records (EHRs) designed to improve interoperability for health information technology (IT) systems used by public health systems and payers.
- Updates to technology and standards for certified EHRs ranging from the capability to exchange clinical images (e.g., X-rays) to the addition of multi-factor authentication support.
- Expansion of the U.S. Core Data for Interoperability data set.
- Updates to the Privacy, Infeasibility, and Requestor Preference Information Blocking Exceptions, and the creation of a new Protecting Care Access Exception.
- Alignment with EHR requirements and CMS Electronic Prior Authorization requirements.
- Revisions to the electronic prescribing certification criterion to include real-time prescription benefit tools.
Clinical Topics: Cardiovascular Care Team
Keywords: Cardiology Magazine, ACC Publications, Centers for Medicare and Medicaid Services, U.S., Cardiac Rehabilitation, Telemedicine, Public Health, Fee Schedules, Health Policy
