The Centers for Medicare and Medicaid Services (CMS) has released the proposed 2025 Medicare Physician Fee Schedule (PFS). Of note, the PFS conversion factor has been updated from $33.2875 to $32.3562, a 2.80% cut. The overall reimbursement for cardiovascular services is projected to remain flat compared with 2024, with changes to policies and individual services roughly balancing out. Individuals and groups will see different impacts depending on patient populations and services offered.

Initial highlights from the proposed rule include:

• A proposal to unwind geographic location telehealth flexibilities that began during the COVID-19 public health emergency and were extended through 2024 by Congress, as required by current law. Several bills under consideration in Congress would extend or make telehealth flexibilities permanent.
• For 2025 and beyond, CMS proposes to allow two-way, real-time audio-only communication to satisfy the requirement for an interactive telecommunications system, when appropriate.
• A proposal to "broaden the applicability of transfer of care modifiers" for 90-day global services. CMS is seeking to more accurately deliver reimbursement of these global services by breaking down payments to preoperative management, surgical care only, and postoperative management only, and is requesting suggestions from stakeholders on how best to implement this.
• A proposal to maintain cardiac rehabilitation services on the telehealth list provisionally through 2025.
• Updated code values for new/revised services, cyclical updates to the Quality Payment Program (QPP), updates to the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) for 2025, the Medicare Shared Savings Program and other payment policy proposals.
• In continuing to seek out ways to incorporate refreshed data to the fee schedule – such as the ongoing American Medical Association Physician Practice Information Survey – CMS has retained the RAND Corporation to develop other methods for measuring practice expenses and updating payments.
• A request for information on sunsetting traditional MIPS and completing the transition to MVPs for the 2027 reporting year/2029 performance period.
• Information request on a potential ambulatory specialty care model that incorporates MVPs to increase specialist engagement in value-based care and expand incentives for primary and specialty care coordination.
• A newly proposed MVP targeting surgical care, which would encompass procedures provided by cardiothoracic surgeons.
• A proposal to require Shared Savings Program Accountable Care Organizations to report the new Advanced Practice Provider Plus quality measure set and to submit their measures through the electronic care quality measure (CQM) or Medicare CQM collection types.

The proposed 2025 Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems rule was also issued today. CMS proposes a 2.6% increase to OPPS payment rates that reflects a market basket update of 3.0% reduced by a productivity adjustment of 0.4%.

The only cardiovascular changes to the ASC covered procedure list (CPL) are the addition of Category III dual-chamber leadless pacemaker codes, indicating no movement on the addition of ablation to the ASC CPL. There are no cardiovascular changes adding or removing services from the inpatient only list.

In the Hospital Outpatient Quality Reporting Program, the Cardiac Imaging for Preoperative Risk Assessment for Non-Cardiac, Low-Risk Surgery measure is proposed for removal beginning with the CY 2025 reporting period/CY 2027 payment determination. CMS states that the measure does not yield sufficiently meaningful data to improve patient outcomes.

Additional information on the proposed rules can be found in the Medicare PFS Press Release, Medicare PFS Fact Sheet, Medicare Shared Savings Program Fact Sheet and QPP Fact Sheet. The OPPS Press Release and OPPS Fact Sheet are also available.

ACC Advocacy staff will provide a more detailed breakdown of the proposed rules in the coming days. Look for updated information on ACC.org/Advocacy and in upcoming issues of The Advocate newsletter.

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Fee Schedules, Physicians, Policy, Outpatients