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CY 2025 Medicare PFS Proposed Rule: A High-Level Summary for ASRA Pain Medicine Members

Sep 30, 2024, 08:17 AM by Edgar Remotti, MD, Trent Emerick, MD, MBA


The CY 2025 Medicare Physician Fee Schedule (PFS) proposes a 2.8% reduction in the Medicare Physician Conversion Factor (CF), continuing a trend of payment reductions over several years. The AMA has emphasized the widening gap between Medicare payments and the cost of delivering care, urging Congress to pass reforms that would permanently strengthen Medicare.

Key Points:

  1. Payment Reductions: The proposed CF for CY 2025 is $32.3562, reflecting a 2.79% decrease from 2024. This reduction, despite rising operational costs, will continue to financially strain physician practices.
  2. Specialty Impact: While specific specialties, such as Interventional Pain Management, show no changes in RVUs, the reduction in CF will still decrease overall reimbursement.
  3. Updates and New Codes: The proposal includes new codes for emerging pain management techniques, such as fascial plane blocks, and updated payment rates for Evaluation and Management (E/M) services, generally reflecting slight reductions.

Table: Proposed Payment Rates for Fascial Plane Blocks

CPT Code Long Descriptor 2025 Proposed Non-Facility Payment 2025 Proposed Facility Payment
6XX07Thoracic fascial plane block, unilateral; by injection(s), including imaging guidance, when performed $119.39$63.09
6XX08Thoracic fascial plane block unilateral continuous infusion(s), including imaging guidance, when performed $221.96$73.45
6XX09
Thoracic fascial plane  block, bilateral; by  injection(s),  including  imaging
guidance, when  performed
$138.48$70.54
6XX10
Thoracic fascial plane  block, bilateral; by  continuous infusion(s),  including imaging  guidance, when  performed
$338.77$77.01
6XX11
Lower extremity  fascial plane  block, unilateral; by  injection(s),  including
imaging guidance,  when performed
$113.25$56.62
6XX12
Lower extremity  fascial plane  block, unilateral; by  continuous  infusion(s),  including  imaging  guidance,  when  performed
$219.38$70.54

 

4. Telehealth Changes: Many COVID-19 telehealth flexibilities are set to expire by the end of 2024, potentially reducing access to remote care unless Congress intervenes.

5. G2211: CMS proposes to allow expanded reporting of the outpatient E/M visit complexity add-on code G2211. G2211 can be applied for outpatient visits for complex, longitudinal care, in which the pain physician serves as a central point of care. Further Reading.

6. Medicare Economic Index (MEI): The MEI is expected to increase by 3.6%, highlighting the misalignment between practice cost inflation and Medicare payment adjustments.

7. Payment Rates:

Table: Proposed Payment Rates for E/M Services

Code
2024 Final
Non-Facility
Payment
2025
Proposed
Non-Facility
Payment
$ Change% Change
2024 Final
Facility
Payment
2025
Proposed
Facility
Payment
$ Change
Change
99202$71.05$70.22-$0.83-1%$46.17$45.30-$0.87-2%
99203$109.69$109.38-$0.320%$79.90$79.28-$0.61-1%
99204$164.38$164.07-$0.310%$129.99$129.44-$0.550%
99205$216.77$216.16-$0.600%$176.82$176.04-$0.780%


9. Regulatory Updates: The AMA response highlights the importance of ongoing regulatory developments, including the expansion of telehealth and advanced primary care models, interoperability standards, and changes to the HIPAA Security Rule.

10. MIPS and MVPs: The transition to MIPS Value Pathways (MVPs) continues, with new pathways introduced for various specialties, aiming to streamline reporting and improve the relevance of performance measures.

11. Request for Information (RFIs): CMS is seeking feedback on various emerging healthcare delivery models, including new payment structures and integration of social determinants of health.

12. Advocacy and Public Comments: The AMA urges physicians to engage in the public comment process to influence the final rule and address the financial challenges posed by ongoing Medicare payment reductions.

 

Further Reading:


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