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