September 13, 2024
Last week, the Post-Acute and Long-Term Care Medical Association (PALTmed) submitted comments to the Centers for Medicare & Medicaid Services (CMS) for the Calendar Year 2025 Physician Fee Schedule Proposed Rule. For 2025, CMS is proposing a cut to physician payment by 2.80% with a reduction of the conversion factor from $33.2875 (2024) to $32.3562 (2025). The cut to Medicare physician payments would begin January 1, 2025, along with estimated rises in costs of practicing medicine, as measured by the Medicare Economic Index (MEI), which will increase by 3.6%. In other words, while the costs of paying clinical and administrative staff, and purchasing equipment and supplies are projected to rise by 3.6%, physicians’ payments will decrease by nearly 3%.
“This proposed rule is silent on the impact of the growing gap between what Medicare pays for care and what it costs to provide that care. It is past time for CMS to join the chorus of authorities on the Medicare program in expressing concern about the ability of patients to continue receiving high-quality care as physician payments erode. We urge CMS to call on Congress to enact a permanent, annual inflation-based update to Medicare physician payments tied to the MEI. At a minimum, CMS must be fully transparent with the public about the impact of these payment cuts by including the expiration of temporary statutory increases to the conversion factor in the specialty impact table,” PALTmed stated in its letter.
PALTmed also noted its support for H.R. 2474, the Strengthening Medicare for Patients and Providers Act, which is bipartisan legislation that would provide an annual physician payment update in Medicare tied to the MEI.
Other key issues PALTmed noted in its letter included supporting CMS’ proposal to remove the telehealth services frequency limitations for subsequent nursing facility visit codes (99307-99310) for CY 2025. “While CMS continues to gather more data on how practice patterns are evolving, we continue to recommend that CMS permanently remove the frequency limit on physicians furnishing subsequent nursing facility visits via telehealth,” PALTmed noted.
PALTmed also asked CMS for clarification on site of services for the newly proposed set of codes for Advance Primary Care Management (APCM) services described by three new HCPCS G-codes. “It has often not been clear whether newer codes are billable in PALTC settings – nursing facilities, home health, and assisted living. We understand that these are to be considered a ‘designated care management service’ under § 410.26(b)(5) and, as such, could be provided by auxiliary personnel under the general supervision of the billing practitioner. However, given the unique nature of the PALTC setting, it is not clear if these can be utilized and how best to utilize them.”