CY 2025 Medicare PFS Proposed Rule: A High-Level Summary for ASRA Pain Medicine Members
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:
- 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.
- Specialty Impact: While specific specialties, such as Interventional Pain Management, show no changes in RVUs, the reduction in CF will still decrease overall reimbursement.
- 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 |
6XX07 | Thoracic fascial plane block, unilateral; by injection(s), including imaging guidance, when performed | $119.39 | $63.09 |
6XX08 | Thoracic 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 | -$0.32 | 0% | $79.90 | $79.28 | -$0.61 | -1% |
99204 | $164.38 | $164.07 | -$0.31 | 0% | $129.99 | $129.44 | -$0.55 | 0% |
99205 | $216.77 | $216.16 | -$0.60 | 0% | $176.82 | $176.04 | -$0.78 | 0% |
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: