CMS Releases the Medicare Physician Fee Schedule Final Rule for 2025
On Friday, November 1, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2025 Medicare Physician Fee Schedule final rule and fact sheet. Below is a summary of some of the major provisions that will affect gynecologic oncologists.
Conversion Factor
The conversion factor for 2025 is set to decrease by 2.83% from $33.2875 to $32.3465. The cut is driven by the expiration of the conversion factor increase that Congress passed in March, coupled with a 0% baseline update. Since CMS does not have statutory authority to eliminate or reduce this payment cut, the SGO has endorsed the Medicare Patient Access and Practice Stabilization Act of 2024, which would eliminate the entire conversion factor cut and provide an update equal to half of the Medicare Economic Index for 2025. Besides supporting this legislative fix for 2025, the SGO continues to work diligently to advocate for Congress to enact permanent policy changes to the conversion factor update, and to ensure that the conversion factor reflects the costs of providing care to Medicare beneficiaries.
HIPEC Services
CMS finalized the RUC-recommended work RVUs HIPEC services reported with Category I CPT® codes 96547 (Intraoperative hyperthermic intraperitoneal chemotherapy (HIPEC) procedure, including separate incision(s) and closure, when performed; first 60 minutes (List separately in addition to code for primary procedure) and 96548 (Intraoperative hyperthermic intraperitoneal chemotherapy (HIPEC) procedure, including separate incision(s) and closure, when performed; each additional 30 minutes (List separately in addition to code for primary procedure). Effective January 1, 2025, code 96547 will have a work RVU of 6.53, and code 96458 will have a work RVU of 3.00.
Global Surgical Package Changes Includes a New HCPCS Add-on Code
CMS finalized two changes that will allow the agency to collect information on the resources involved in providing global surgical services and the associated follow-up visits.
Differing slightly from the proposed policies which would have broadened the use modifiers -54 (surgical care only), -55 (post-operative management only), and -56 (preoperative management only). CMS has finalized the use of modifier -54 (surgical care only) and will require modifier -54 be applied to all “90-day global surgical packages in any case when a practitioner plans to furnish only the surgical procedure portion of the global package (including both formal and other transfers of care).” For modifiers -55 and -56, there are no policy changes, and those modifiers should be used only when there is a documented formal transfer of care.
CMS finalized the creation of HCPCS code G0559, an add-on code used to report services for post-operative care provided to a Medicare beneficiary by a practitioner that did NOT perform the surgical procedure. The code was created by the agency to capture the time and resources required in these cases. The code may only be appended to an office E/M service for new or established patients. Also, G0559 is only billable once during the 90-day global period. The final work RVU is 0.16. The complete description, along with the required elements of the new code may be found on page 740 of the display copy of the final rule.
Telehealth Updates
CMS finalized its proposed policy and will not make separate payment for new telehealth E/M CPT® codes which were created by the CPT® Editorial Panel, and subsequently valued by the AMA RUC. CMS continues to believe the new telehealth E/M CPT® codes are duplicative of the current set of E/M CPT® codes. Providers should continue to bill for Medicare telehealth services by reporting the appropriate E/M code and using place of service indicators and modifiers.
CMS finalized the definition of an interactive telecommunications system to include two-way, real-time audio-only. Beginning January 1, 2025, interactive telecommunications system may include communication technology, or any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system, but the Medicare beneficiary may not be capable or may not consent to the use of video technology, therefore real-time audio-only would be an acceptable means to deliver the telehealth service.
Additionally, CMS finalized the definition of direct supervision for certain services that allows the physician or supervising practitioner to provide supervision through real-time audio and visual interactive telecommunications. The agency finalized policy that allows teaching physicians to supervise residents virtually in teaching settings. This policy will run through December 31, 2025.