The Centers for Medicare and Medicaid Services (CMS) has released the 2025 Medicare Physician Fee Schedule proposed rule and fact sheet. The rule once again features more payment cuts as the Congressional assistance given over the past few years comes to an end.

Conversion Factor

For 2024, CMS is proposing a conversion factor of $32.36, compared to $33.29 in 2024, a decrease of 2.8% that CMS acknowledges stems from the expiration of the Congressional payment increase, a zero percent annual update, and adjustments to account for changes in work valuation. 

Million Hearts

CMS is proposing to take lessons learned from some of its value-based care models and incorporate those concepts into the fee schedule. One of these areas focuses on atherosclerotic cardiovascular disease (ASCVD) risk and the lessons learned from the Million Hearts model. CMS is proposing new codes for both ASCVD risk assessment and management to be used in conjunction with an evaluation and management service. 

Global Payments

CMS is proposing to require that the transfer of care modifiers (54, 55, 56) be used any time the proceduralist is only performing a portion of the global care (pre-op, post-op) for a procedure with a 90-day global period. CMS is also proposing an add-on code to be used by practitioners seeing the patient for post-operative care who were not involved in performing the procedure. 

G2211 

In 2024, CMS brought back the add-on code, G2211, which is used in addition to evaluation and management services for additional complexity stemming from primary care or ongoing care of complex chronic conditions. For 2025, CMS is proposing to expand the use of the code to include when a preventative service or immunization is performed on the same day as an evaluation and management service. 

Telehealth

The provisions for site of service (to include the patient’s home outside of mental health services), geography, and provider type expire at the end of 2024. CMS states that telehealth services will revert to pre-pandemic requirements in these areas, barring legislation permitting a continuation of the changes. However, CMS is proposing to continue direct supervision via audio-visual communication for cardiac rehabilitation and other services through 2025. 

CMS will perform a comprehensive review of all codes on the provisional telehealth list to determine which ones warrant permanent telehealth status in future rule-making. 

CMS also reviewed a new telehealth code set presented through the CPT process. CMS is proposing not to value the new telehealth services stating that they are duplicative to the office visit code set that is currently on the telehealth list. 

Changes to Rural Health Clinics (RHCs) and Federally Qualified Health Clinics (FQHCs) 

CMS is proposing to make a change that would require RHCs and FQHCs to provide primary care services. CMS states that this change would allow RHCs and FQHCs flexibility to bring specialty services such as cardiology to rural communities.  

Merit Based Incentive Program (MIPS) 

CMS has proposed to maintain the performance threshold at 75 points for the 2025 performance year. The data completeness threshold will remain at 75 percent through 2028.  
CMS has proposed adding two measures to the Cardiology Specialty Measures set. The measures are 495 Ambulatory Palliative Care Patients' Experience of Feeling Heard and Understood and Adult COVID-19 Vaccination Status. 

CMS has also proposed a new Improvement Activity: Save a Million Hearts: Standardization of Approach to Screening and Treatment for Cardiovascular Disease Risk. 

CMS is proposing to revise the name of ST-Elevation Myocardial Infarction (STEMI) Percutaneous Coronary Intervention (PCI) cost measure to Inpatient (IP) Percutaneous Coronary Intervention (PCI). This change would be to better reflect the inclusion of patients with a non-STEMI and patients with PCI but without a STEMI or non-STEMI. 

MIPS Value Pathways (MVPs) 

CMS is requesting information on the development of a new ambulatory specialty model using the current MVP framework. Single specialties (cardiology) or subspecialties (interventional cardiology) could be chosen for participation. 

CMS has proposed changes to the Advancing Care for Heart Disease MVP including the addition of one quality measure (495 above), one new improvement activity for vaccine status, and one revised cost measure listed above.   

CMS is accepting public comment on the proposed rule for 60 days from the final publication date. SCAI will continue to analyze the rule and will provide comments to CMS. 

SCAI continues to fight the payment cuts through both regulatory and legislative channels. SCAI’s Advocacy Committee and its political arm, SCAI PAC, will be reviewing the effects of these cuts and providing more information to SCAI members for further action in the near future.