July 15, 2024

On July 10, CMS released its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP). APMA staff is reviewing and analyzing the 2,000-plus page proposal. Some of the proposals include: 

• CMS proposes a CY 2025 conversion factor of $32.3562, down approximately 2.8 percent from the CY 2024 conversion factor of $33.2875. This decrease is due to the expiration of the 2024 2.93-percent bump provided by Congress plus a positive budget neutrality adjustment of 0.05 percent triggered by CY 2025 policies. APMA is already collaborating with AMA and others to contest this change.
• Podiatry is anticipated to have a 0-percent combined impact on total allowed charges based on RVU changes for 2025.
• CMS proposes to allow audio-only communication for telehealth services if a patient will not or cannot use a video communication tool. This proposal is something APMA has requested for several years.
• CMS proposes to maintain the performance threshold to avoid a MIPS penalty at 75 points for the CY 2025 performance year/2027 MIPS payment year.

APMA will complete its review in conjunction with consultants and committee members and submit comments to CMS on these proposals. The 2025 Final Rule is expected sometime in November.

For more details, visit:

• CMS Press Release
• CMS CY 2025 MPFS Fact Sheet
• CMS CY 2025 QPP Fact Sheet
• CMS CY 2025 Proposed and Modified MVP Guide
• CMS CY 2025 MSSP ACO Fact Sheet