CY 2025 Physician Fee Schedule Proposed Rule Summary – Part I

On July 10, 2024, CMS placed on public display a proposed rule relating to the Medicare physician fee schedule (PFS) for CY 2025 and other revisions to Medicare Part B policies. The proposed rule was published in the July 31, 2024, issue of the Federal Register. If finalized, policies in the proposed rule generally would take effect on January 1, 2025. The 60-day comment period ends at close of business on September 9, 2024. HFMA is providing a summary in three parts. Part I covers sections I through III.O (except for Section G: Medicare Shared Savings Program Requirements) and the Regulatory Impact Analysis. Part II will cover the Medicare Shared Savings Program Requirements. Part III will cover the updates to the Quality Payment Program. Part I includes payment policies under the PFS, including caregiver training services, the evaluation and management (E/M) office/outpatient (O/O) complexity add-on code, telehealth services, advanced primary care management services, global surgery payment, behavioral health services, dental services, preventive services, such as colorectal cancer and hepatitis B screening, and Inflation Reduction Act provisions relating to Part B drugs and biologicals. The proposed rule contains several comment solicitations, including on services addressing health-related social needs, building upon the MIPS Value Pathways framework to improve ambulatory specialty care, and strategies for implementing recurring updates to direct and indirect practice expense.