The Centers for Medicare and Medicaid Services
(CMS) released the proposed payment regulations for calendar year 2025.
Key among these is a proposed 2.8% cut for physician service.
Our societies will urge Congress to reverse these
unacceptable cuts - and you can help by pushing Congress to adopt
lasting changes that tie physician payments to the Medicare Economic
Index.
Take Action Now!
Six key takeaways for GI:
- Physician payments decline: The
proposed 2.8% cut for physician service in CY 2025 is based on a
conversion factor of $32.36, down from the current CY 2024 conversion
factor of $33.29. Medicare payments currently do not keep up with the
rising costs of inflation and running a practice. An additional cut for
2025 will further harm already overburdened physician practices.
- COVID-19 era telehealth flexibilities end: Absent
Congressional action, CMS is proposing that the statutory restrictions
on geography, site of service, and practitioner type that existed prior
to the COVID-19 PHE will go back into effect beginning Jan. 1, 2025.
Current COVID-19 telehealth flexibilities will remain in place until the
end of CY 2024.
- Telemedicine office visit codes: CMS
proposed not to accept 16 new codes the American Medical Association
(AMA) CPT Editorial Panel created to describe telemedicine office visit
services (9X075-9X090). CMS believes the currently available office
visit codes (99202-99205, 99212-99215) with appropriate modifiers
adequately identify telemedicine for the Medicare program. This is good
news as it will eliminate the need for physicians to learn how to use
and report a new family of CPT codes for telemedicine services and
payment for telemedicine services will remain the same as in-person
visits. CMS does propose to accept 9X091 with the RUC recommended value
of 0.30 work RVUs and it proposes to delete HCPCS code G2012, (Brief
communication technology-based service, e.g. virtual check-in), which
describes a very similar service to 9X091.
- Expanded reporting of office/outpatient (O/O) Evaluation and Management (E/M) visit complexity add-on code G2211: CMS
is proposing to allow payment for G2211 when the O/O E/M base code is
reported by the same practitioner on the same day as an annual wellness
visit (AWV), vaccine administration, or any Medicare Part B preventive
service furnished in the office or outpatient setting. The GI Societies
will advocate for CMS to provide additional clarity on how our members
should use this code.
- Expanded colorectal cancer screening: CMS
is planning updates to covered colorectal cancer (CRC) screenings that
align with the latest evidence-based guidelines. CMS proposes adding
coverage of computed tomography (CT) colonography, while removing
coverage of barium enema. CMS is also proposing to expand their
“complete CRC screening” approach to include either a Medicare-covered
blood-based biomarker test or non-invasive stool-based test, and that a
follow-on colonoscopy after a positive result would not incur
beneficiary cost-sharing. This improves CRC screening access by
encouraging patients to be screened without the fear of a surprise
bill.
- Changes to Quality Payment Program: CMS
is proposing a Gastroenterology Care Merit-based Incentive Payment
System (MIPS) Value Pathway (or MVP) for use beginning with the 2025
performance period. The proposed MVP includes 11 MIPS quality measures
and 3 QCDR measures within the quality performance category, which are
specific to gastroenterology. Currently, MVP reporting is a voluntary
alternative that CMS hopes will reduce administrative burden. Our
societies previously encouraged CMS to start with a narrowly focused GI
MVP addressing a singular clinical condition, specifically colorectal
cancer prevention. The proposed MVP includes a broad set of GI-related
measures related to colonoscopy, hepatitis and inflammatory bowel
disease.
CMS also proposes
removing the Age-Appropriate Screening Colonoscopy measure from the
gastroenterology specialty measure set for MIPS. The GI societies
previously conveyed to CMS this measure should continue to be available
for clinician reporting through MIPS.
Key CY 2025 HOPD/ASC takeaways for GI:
- Hospital and ASC payments increase: CMS
proposes updating OPPS and ASC payment rates for hospitals that meet
applicable quality reporting requirements by 2.6%. This update is based
on the projected hospital market basket percentage increase of 3.0%,
reduced by a 0.4 percentage point productivity adjustment.
- Changes to colonoscopy cost sharing:
Like the proposed changes for physicians, CMS proposes to codify its
definition of “CRC screening tests” to include a follow-on screening
colonoscopy after a positive blood-based colorectal cancer (CRC)
screening test. This change aims to eliminate patient cost-sharing for
facility fees, ultimately improving access to care and cancer
prevention.
- Quality: A number of proposals
have been made to update and refine facility quality reporting programs.
Our societies will comment on the feasibility and associated
administrative burden of some proposals.
Resources
CMS Medicare Physician Fee Schedule Proposed Rule and Fact Sheets
2025 Physician Fee Schedule Proposed Rule
2025 Physician Fee Schedule Proposed Rule Press Release
2025 Physician Fee Schedule Proposed Rule Fact Sheet
2025 MPFS Proposed Rule GI Payment Changes
2025 MPFS Proposed Physician Work, PE and RVU Changes
CMS Hospital Outpatient and ASC Proposed Rule and Fact Sheets
2025 OPPS/ASC Payment System Proposed Rule
2025 OPPS/ASC Payment System Proposed Rule Fact Sheet
2025 OPPS/ASC Payment System Proposed Rule Press Release
2025 Proposed ASC Payment Rates
2025 Proposed ASC Top 10 Base and Biopsy Codes
2025 Proposed Hospital Outpatient Payment Rates
2025 Proposed Hospital Outpatient Top 10 Base and Biopsy Codes