CMS Releases 2025 Medicare Fee Schedule Proposal

The Centers for Medicare & Medicaid Services (CMS) has proposed a 2.8% cut in payments for 2025 under the Physician Fee Schedule (PFS), continuing a decade-long trend that has seen the Medicare fee schedule reduced by nearly 10%.

Why it matters: The proposed cuts could impact patient access to care and the sustainability of physician practices, prompting urgent calls for congressional action to reform the Medicare Physician Payment System.

The details:

• The Conversion Factor (CF) in the 2025 Proposed Rule is $32.3562, compared with the current $33.2875.
• CMS estimates indicate that most of radiology will be minimally impacted (0%) by the rule, while interventional radiology could see a 2% decrease.
• CT colonography (CTC) will become a covered service for Medicare beginning in 2025, based on guidelines from the U.S. Preventative Services Task Force.
• Direct supervision of certain procedures will continue to be allowed via two-way audio/video communications technology through December 31, 2025.

The American Medical Association (AMA), along with all 50 state medical societies and 76 other health organizations, is urging Congress to pass critical legislation to ensure the sustainability of physician practices.

What they’re saying:

• “The current Medicare Physician Payment System is increasingly unsustainable, and the necessary policy reforms can no longer be delayed without severe repercussions for patient access and quality of care,” the letter from the AMA and other organizations states.
• The letter emphasizes that refining the Medicare Physician Fee Schedule to reflect the fiscal and clinical realities of today’s medical practice is foundational to strengthening the current payment system.

The other side: While there was hope for legislative corrections to improve the MPFS rate-setting methodology, significant changes appear unlikely for 2024.

What’s next: The Proposed Rule is generally a good indicator of the Final Rule, typically with minor adjustments. Any relief from the 2.8% cut will likely follow similar intervention patterns seen in previous years. The final rule is expected to be released around Nov. 1, with the proposed changes taking effect on Jan. 1, 2025.

Full story

The Centers for Medicare & Medicaid Services (CMS) has released a proposed rule for the 2025 Physician Fee Schedule (PFS). The rule includes a 2.8% cut in payments, continuing a decade-long trend that has seen the Medicare fee schedule reduced by nearly 10%. Last year’s proposed rule for 2024 initially contained a 3.36% cut, which was reduced to 1.77% after Congress intervened.

Similar actions may occur again this year. The Conversion Factor in the 2025 Proposed Rule is $32.3562, down from the current $33.2875. CMS estimates indicate that most of radiology will see minimal impact (0%), but interventional radiology could face a 2% decrease.

These estimates do not account for potential Congressional adjustments. The proposed rule does include some positive news. CT colonography (CTC) will become a covered service for Medicare starting in 2025.

CMS is using authority under the Balanced Budget Act of 1997 to add CTC to its definition of colorectal cancer screening tests, based on guidelines from the U.S. Preventative Services Task Force. The rule also removes coverage for the double-contrast barium enema, which CTC has largely replaced. Direct supervision of certain procedures via two-way audio/video communications technology will continue to be allowed through December 31, 2025.

CMS is evaluating the impacts on patient safety and quality of care before making this change permanent.

Changes to Medicare fee schedule

The PFS changes also cover rules for the Quality Payment Program (QPP).

Radiology practices often participate in QPP through the Merit-based Incentive Payment System (MIPS). Changes to MIPS scoring for 2025 may have positive effects on radiology practices. MIPS Value Pathways (MVPs) have been proposed based on existing Specialty Measure Sets.

These would serve as a bridge until new measures are available to support individual MVPs for radiology. CMS also proposes removing the 7-point cap on any Quality Category measure that is part of a specialty, allowing such measures to receive the full 10 points. Specific diagnostic radiology measures are included in this provision.

Several aspects of MIPS rules remain unchanged for 2025. The MIPS Performance Threshold will stay at 75 points, and the 75% data completeness criteria will be maintained through 2028. Performance categories’ weights will remain at 30% Quality, 15% Improvement Activities, and 25% Promoting Interoperability.

The Small Practice bonus stays at 6 points in the Quality Category. The Proposed Rule is generally a good indicator of the Final Rule, with minor adjustments. Significant changes appear unlikely for 2024, and any relief from the 2.8% cut will likely follow similar intervention patterns seen in previous years.

Further analysis will be provided when the Final Rule is issued.