The ACC submitted formal comments on the proposed 2025 Medicare Physician Fee Schedule (PFS) to the Centers for Medicare and Medicaid Services (CMS) on Sept. 9, providing feedback on several issues of relevance to the cardiovascular community.   

Of note, the College reiterated its opposition to the proposed 2.8% reduction to the conversion factor and expressed strong support for the Strengthening Medicare for Patients and Providers Act (H.R. 2474), a bill that would provide annual inflationary updates to the PFS equal to the Medicare Economic Index. This trend of declining payments and rising costs for practices is unsustainable, and the ACC continues to push for action by Congress that would foster a more stable Medicare payment system. 

Other highlights from the College’s comments include: 

• Telehealth Policy: The ACC supports the proposed one-year extension of cardiovascular and pulmonary rehabilitation on the Medicare Telehealth Services List and urges its inclusion be made permanent. The College also supports extending direct supervision via two-way audio-visual communications technology as well as the continuation of practitioners using their currently enrolled practice location instead of their home address when providing services from their home. 
• Cardiac CT: Cardiac computed tomography (CT) reimbursement in the Medicare PFS is subject to a statutory cap equal to the reimbursement under the Hospital Outpatient Prospective Payment System (OPPS). The 2025 Hospital OPPS final rule may increase this reimbursement. As such, the ACC requests CMS enact a corollary increase in cardiac CT in the Medicare PFS should this occur. 
• New ASCVD Risk Assessment and Risk Management G Codes: The ACC supports newly created add-on codes that provide reimbursement for risk assessments and risk management of patients with moderate to high risk of developing atherosclerotic cardiovascular disease (ASCVD). The proposal is based on the success of the Million Hearts™ Model and recommends utilizing ACC-developed risk assessment tools. 
• Global Payment Policy Accuracy: The ACC supports CMS efforts to accurately and appropriately allocate resources while imploring CMS to update the post-operative Evaluation/Management code inputs included in 10-day and 90-day global codes to their recently updated values.  
• MIPS to MVP Transition: The ACC provides detailed feedback on the proposed transition from the Merit-based Incentive Payment System (MIPS) to MIPS Value Pathways (MVPs) to occur by 2029.  

You can read the ACC’s full comment letter here. For more information on the proposed 2025 Medicare PFS, access the full text or the accompanying press release, fact sheet, Medicare Shared Savings Program Fact Sheet and Quality Payment Program Fact Sheet. CMS will consider comments and post a final rule with any changes around Nov. 1. The final rule will take effect on Jan. 1, 2025. 

Plus, explore the ACC’s Regulatory Affairs Roadmap for more on how the College responds to regulatory rulings and advocates on behalf of its members.

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Fee Schedules, Physicians