Harmful Medicare cuts proposed for 2025

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.

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.

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.

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.

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.

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.