CMS Releases 2025 Physician Fee Schedule Proposed Rule

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.

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The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service outpatient prospective payment system effective Jan. 1, 2025. The proposed rule: Provides a net 2.3% increase …


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Most Hospitals Fall Short on Affordability, Vision and Trust

“This weekend, the American Hospital Association kicks-off its annual Leadership Summit in San Diego. Its agenda is organized around 8 themes: Transforming Care Delivery and Payment, Patient Centricity Through Digital Transformation, Building a More Flexible and Sustainable Workforce, Financial and Operating Excellence, Igniting Innovation, Elevating Health Equity, Improving Behavioral Health and Governance Excellence. They’re important. …

Collectively, that’s welcome news for a nation that’s anxious and divided. The current state in U.S. healthcare is much the same. It needs its hospitals to step up.

Some Boards and their hospital leadership teams take affordability, vision and trust seriously. Some don’t.”

Paul Keckley, July 15, 2024


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The MHA received media coverage the week of July 15 on healthcare priorities in Michigan, the state budget and the intersection between public health and healthcare. Hillsdale Hospital published an episode of the Rural Health …

 

CMS Releases Medicare 2025 Outpatient Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service outpatient prospective payment system (OPPS) effective Jan. 1,  2025.

The proposed rule:

  • Provides a net 2.3% increase to the OPPS conversion factor from $87.38 to $89.38 for hospitals that report quality measure data.
  • Increases the outlier fixed-dollar threshold by 3.2% from the current $7,750 to $8,000.
  • Modifies the timeframe for standard review of prior authorization requests for hospital outpatient department services from 10 business days to seven calendar days.
  • Uses 2023 claims data and the most updated cost report data from the healthcare cost report information system, primarily from 2022, to set payment rates.
  • Adds three services (CPT codes 0894T, 0895T and 0896T) for liver allograft-related procedures to the 2025 Inpatient-Only List.
  • Updates the core based statistical areas used to determine a hospital’s wage index, consistent with other 2025 proposed rules.
  • Adds two new status indicators (H1 and K1) to identify healthcare common procedure coding system/current procedural terminology (HCPCS/CPT) codes representing separately payable, non-opioid post-surgical pain management products as authorized by the Consolidated Appropriations Act of 2023.
  • Establishes separate payment for diagnostic radiopharmaceuticals with a per-day cost exceeding $630.
  • Excludes qualifying cell and gene therapies from comprehensive ambulatory payment classification packaging.
  • Adopts three measures related to health equity for the Outpatient, ambulatory surgical center (ASC) and rural emergency hospital quality reporting programs, and extending voluntary data reporting for two hybrid measures in the inpatient quality reporting program.
  • Establishes new conditions of participation for hospitals and critical access hospitals focused on obstetrical services and maternal care.
  • Extends the virtual direct supervision of therapeutic and diagnostic services under the physician fee schedule (PFS) through Dec. 31, 2025. The CMS also proposes to extend virtual direct supervision under the OPPS through Dec. 31, 2025, to maintain alignment between the PFS and OPPS.
  • Adds 20 medical and dental procedures to the ASC covered procedures list.
  • Updates the hospital outpatient quality reporting program requirements.
  • Updates requirements for the rural emergency hospital quality reporting program.

The MHA will provide a hospital-specific impact analysis within the next few weeks and encourages members contact Vickie Kunz by Aug. 30 regarding issues identified. Hospitals are encouraged to review the proposed rule and its impact on operations 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.

MHA Webinar Reviews CMS Medication Administration and Management Requirement Updates

The MHA is hosting the webinar CMS Medication Administration and Management: IV Medication, Blood Administration and Safe Opioid Use from 10 a.m. to noon ET Aug. 27.

Knowing medication is involved in 80% of treatment plans, hospitals and healthcare organizations are closely monitored by the Centers for Medicare & Medicaid Services (CMS) on how they are administered. Healthcare teams looking to assess and strengthen their medication dispensing protocol and ensure CMS compliance are encouraged to attend the webinar, which will cover:

  • Updated CMS guidelines on medication administration and safe opioid use.
  • Specific time frames that medications must be administered.
  • CMS policy and education requirements on medication administration and safe opioid use.
  • CMS requirements to ensure staff are competent when performing IV medications or blood transfusions.

MHA members can register for a $195 connection fee. Those interested in attending are encouraged to register by noon Aug. 26. Members with questions should contact Brenda Carr at the MHA.

2025 Medicare Fee-for-Service Home Health Proposed Rule Released

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the home health (HH) prospective payment system (PPS) for calendar year (CY) 2025. The rule includes updates to the Medicare fee-for-service HH PPS payment rates based on changes by the CMS and those previously adopted by Congress.

Highlights of the proposed rule, which takes effect Jan. 1, 2025, include:

  • A negative 4% adjustment to base payment rates to achieve budget neutrality following the transition to the Patient-driven Groupings Model (PDGM).
  • A 30-day standard payment rate of $2,008.12 ,down 1.5% from the current $2,038.13, for HH agencies that submit the required quality data.
  • Updating core-based statistical areas for wage index purposes, consistent with recent fiscal year 2025 proposed rules.
  • Recalibrating the PDGM case-mix weights, low utilization payment adjustment thresholds, functional levels and comorbidity adjustment subgroups.
  • Revising the fixed dollar loss ratio from 0.27 to 0.38, reducing outlier payments.
  • Requiring HH agencies to report four new patient assessment items in the HH agency Outcome and Assessment Information Set under the social determinants of health category, beginning CY 2027.
  • Adding a new standard within the Medicare Conditions of Participation requiring HH agencies to develop, implement and maintain a patient acceptance to service policy that is applied consistently to each prospective patient referred for HH care.
  • Requiring long-term care facilities to report respiratory illness data as part of their infection prevention and control programs. The CMS proposes that facilities would electronically report weekly data on COVID-19, influenza and RSV in a standardized format through the National Healthcare Safety Network.
  • Requesting information on:
    • HH quality reporting program measure concepts under consideration for future years.
    • Future performance measure concepts for the expanded HH value-based purchasing model.
    • Rehabilitative therapists conducting the initial and comprehensive assessment.
    • Plan of care development and scope of services HH patient receive.

Members are encouraged to review the proposed rule and contact Vickie Kunz by Aug. 19 regarding issues. Comments are due to the CMS Aug. 26, 2024, and can be submitted electronically. The MHA will provide an estimated impact analysis in the near future.

Members with questions should contact Vickie Kunz at the MHA.