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CMS releases proposed rule for 2025 physician fee schedule; conversion factor cut by 2.8%, telehealth waivers extended, behavioral health payments expanded

July 10, 2024 (press release) –

The Centers for Medicare & Medicaid Services July 10 released its calendar year 2025 proposed rule for the physician fee schedule. The rule proposes to cut the conversion factor by 2.8%, to $32.36 in CY 2025, as compared to $33.29 in CY 2024. This reflects the expiration of the 2.93% statutory payment increase for CY 2024; a 0.00% conversion factor update under the Medicare Access and Children’s Health Insurance Program Reauthorization Act; and a .05% budget-neutrality adjustment.

CMS also makes several proposals designed to improve payment for and access to behavioral health care services. This includes a proposal to expand payments for opioid treatment programs for new FDA-approved overdose reversal medications and extend flexibilities for the use of telehealth modalities by OTPs.

In addition, CMS proposes extension of certain telehealth waivers through 2025 including the waiver allowing for reporting of enrolled practice address instead of home addresses when providers perform services from their home, the waiver for federally qualified health centers and rural health clinics to bill for telehealth services, and the waiver for virtual supervision for residents in all teaching settings when the services are provided virtually.

For the Quality Payment Program, CMS proposes six new, optional Merit-based Incentive Payment System Value Pathways for reporting beginning in 2025. CMS also solicits comment on whether to mandate MVP participation beginning with the CY 2029 reporting period.

CMS also includes proposals regarding the Medicare Shared Savings Program. For example, it would mitigate the impact of significant, anomalous, and highly suspect (SAHS) billing activity for CY 2024 and subsequent years. Specifically, CMS proposes to exclude payment amounts from financial calculations for the relevant calendar year for which the SAHS billing activity is identified, as well as from historical benchmarks used for reconciliation.

CMS will accept comments on the proposed rule through Sept. 9. AHA members will receive a Special Bulletin with more details July 11.

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