The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the physician fee schedule (PFS) payment system effective Jan. 1, 2025.
The proposal would:
- Reduce the PFS conversion factor by a net 2.8% from the current $33.29 to $32.36 after expiration of the 2.93% statutory payment increase for 2024 and a 0% conversion factor update.
- Refine guidance regarding the complexity add-on code (G2211) for payment of evaluation and management visits.
Extend certain telehealth waivers through 2025 including:
- Allowing providers to report enrolled practice addresses instead of home addresses when services are performed from their home.
- Defining direct supervision to include virtual presence via audio/video real-time communications technology.
- Revise the data reporting period and phase-in of payment reductions for clinical laboratory tests under the clinical laboratory fee schedule by updating the data reporting period to Jan. 1 – March 31, 2025.
- Extending the phase-in of payment reductions by an additional year meaning that 2024 payments cannot be reduced below 2023 amounts and 2025-2027 payments cannot be reduced more than 15% compared to the previous year.
- Delay implementation of the CMS’ rebased and revised Medicare economic index until future rulemaking.
- Codify policies established in revised guidance for Medicare Part B and Part D drug inflation rebate programs and propose new and revised policies for these programs.
- Exclude suspected anomalous spending from financial calculation for the Medicare Shared Savings Program (MSSP).
- Add six new measures to the MSSP measure set and streamline reporting options
- Add six new optional merit-based incentive payment system value pathways for 2025.
The MHA encourages members to contact Vickie Kunz by Aug. 30, regarding issues identified. Hospitals are encouraged to review the proposed rule and submit comments to the CMS by Sept. 9. The CMS is expected to release a final rule around Nov. 1, for the Jan. 1, 2025, effective date. Members with questions may contact Vickie Kunz at the MHA.