What to Know About Proposed Changes for Physician Payment
August 5, 2024
The Centers for Medicare & Medicaid Services (CMS) released its proposed 2025 Medicare Physician Fee Schedule (PFS) in July. While the proposed rule includes various positive developments for neurology, the fee schedule once again included a cut to reimbursement for who bill Medicare.
The AAN, which meets regularly with CMS leaders, submits comment letters, and advocates for neurologists and their patients, has an in-depth summary of the proposed rule. Here’s a quick summary of the most important points for neurologists to know.
How Does the Proposal Affect Payment to Neurology?
The proposed rule includes a 2.8% cut to the PFS conversion factor, reflecting the phase-out of temporary relief measures and the impact of statutory budget neutrality requirements. While CMS can propose policies—including some that significantly impact the field of neurology—an act of Congress is needed to address the issues behind the cut.
By addressing budget neutrality triggers and providing a permanent, inflation-based positive update to the 2025 Physician Fee Schedule and beyond, Congress can end the constant cycle of cuts. This intervention would help keep neurological practices stable and ensure patient access to care despite the effects of inflation.
Members can use the AAN Advocacy Action Center to easily contact their representatives and urge them to prevent harmful reimbursement cuts in 2025 and beyond. The AAN sent a letter to congressional leadership in July to request they fix impending cuts to physician reimbursement.
Despite the statutory cut to the conversion factor, CMS expects that proposals under its control will have a net 0% impact on overall payment to neurology.
Telehealth
The proposed rule included several positive telehealth updates.
First, CMS proposed that “interactive telecommunications system” be redefined to include two-way, real-time, audio-only communications in 2025 and beyond. This change would help promote access to audio-only telehealth services for Medicare beneficiaries.
Second, the rule would extend a number of telehealth flexibilities originating from the COVID-19 Public Health Emergency (PHE). During the PHE, CMS allowed practitioners to perform telehealth visits from their homes without reporting their home address on publicly available Medicare enrollment files. Citing privacy and safety concerns, the agency is proposing that this flexibility continue rather than expiring at the end of 2024.
Next, CMS is acting on the AAN’s recommendation to maintain parity for in-person and telehealth services. The agency decided not to recognize a new telehealth CPT code set for audio-only and audiovisual E/M codes for payment under Medicare, which would have significantly changed coding and billing for telehealth services and reduced payment for higher-level and audio-only visits. Instead, the agency will continue to pay for telehealth E/M services using the existing office/outpatient codes that are currently on the Medicare telehealth services list. Billing will include the appropriate place of service code for the beneficiary’s location and, when applicable, the appropriate modifier for audio-only services.
CMS is also proposing a policy for virtual direct supervision, but only for a subset of incident-to services that are deemed lower-risk. However, citing concerns about an abrupt return to pre-PHE policies, CMS will keep allowing direct supervision defined by the presence and “immediate availability” of the supervising practitioner via real-time audio and video through December 31, 2025.
Finally, CMS is proposing an extension of its policies allowing teaching physicians to have a virtual presence during the key portion of the Medicare telehealth service for which payment is sought, when the patient, resident, and teaching physician are all in separate locations using real-time audiovisual communications technology. The policy, which excludes audio-only technology, would be extended through December 31, 2025.
Other Updates
Other proposals include:
- Minor modifications to the G2211 complexity add-on code, removing restrictions that prohibited its use by the same practitioner on the same day as an annual wellness visit, vaccine administration, or any Medicare Part B preventative service in the office or outpatient setting
- Establishing new coding and payment for caregiver training for direct care services and supports as well as caregiver behavior management and modification training
- Implementing requirements under the Inflation Reduction Act under which drug manufacturers must pay inflation rebates if they raise the price of certain Part B and Part D drugs higher than the rate of inflation
- Several changes to Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs)
- Combining the “Optimal Care for Patients with Episodic Neurological Conditions” and “Supportive Care for Neurodegenerative Conditions” MVPs
- Keeping the “Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes” MVP available with minor modifications
- Making six new MVPs in ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care available in the 2025 performance period
The AAN is constantly advocating for neurologists, neurology professionals, and their patients, and it is also responding to the proposed rule. Browse priority issues, position statements, and comment letters, or read the full summary of the proposed rule.