CY2025 Medicare Physician Fee Schedule Summary

On November 1, the Centers for Medicare & Medicaid Services (CMS) issued the CY2025 Medicare Physician Fee Schedule final rule which includes updates to physician payment policies, the Quality Payment Program (QPP), and the Medicare Shared Savings Program (MSSP). Most significantly, CMS has reduced the CY2025 conversion factor by 2.83 percent from $33.288 to $32.347. The anesthesia conversion factor will also decrease from $20.774 to $20.318. These reductions, which apply to services across the fee schedule, are the result of statutorily mandated reductions, which the AOA has been fighting to address through legislation.

Despite the statutorily required reductions to the conversion factor, the rule reflects a commitment from CMS to support payment for longitudinal, coordinated care. Key takeaways from the fee schedule include the following:

     • CMS continues to support payment for comprehensive primary care, and has created several new opportunities for payment, including enabling the G2211 evaluation/management care complexity add-on code to be billed with Medicare preventive services, as well as the creation of new Advanced Primary Care Management (APCM) codes;
    • Recognizing telehealth services remain a critical way for patients to access care, CMS has finalized a range of policies promoting access to telehealth, pending Congressional extension of COVID-19 era statutory flexibilities, including continuing payment for telehealth services at parity with in-person services, paying for audio-only services, and finalizing additional flexibilities; and
     • CMS continues to expand payment for vital mental and behavioral health services, including payment changes for opioid treatment programs, standalone G codes and payment for safety planning interventions and follow-up services post-discharge for a crisis encounter.

Changes related to surgical care include new requirements for reporting transfer of care modifiers – raising concerns for future changes to surgical payment. CMS also created a new code to capture the time and resources spent providing post-operative care within a 90-day global period by a physician who did not perform the surgical procedure.

The rule also contains a range of changes to the QPP and MSSP. Overall, CMS has made modifications to measure lists across the Merit Based Incentive Payment System (MIPS) performance categories and made substantial changes to the MIPS value pathways. Additionally, following AOA advocacy CMS will maintain the MIPS performance threshold, upon which payment adjustments are determined, at 75 points. AOA expressed concern that raising the performance threshold would disadvantage small and independent practices, especially those who applied for extreme and uncontrollable circumstance exemptions from the MIPS program through 2024 and who are now just resuming participation. However, CMS’ strong interest in driving participation in MIPS Value Pathways, and ultimately sunsetting traditional MIPS by 2029, remains a concern.

Read the full summary from the AOA here