The Centers for Medicare & Medicaid Release CY 2025 Proposed Rule for the Medicare Physician Fee Schedule

On Wednesday, July 10, the Centers for Medicare & Medicaid Services (CMS) released the CY 2025 Medicare Physician Fee Schedule (MPFS) proposed rule and fact sheet. The following is a high-level summary of the policies that will affect SGO members. SGO will be reviewing the proposed rule and submitting comments in advance of the September 9 deadline.

Conversion Factor

The conversion factor for 2025 is set to decrease by approximately 2.80% from $33.2875 to $32.3562. The cut is primarily driven by the expiration of the conversion factor increase that Congress passed in March.

CMS Accepted RUC Recommendations for New CPT® Codes

The SGO continues to serve our members by collaborating with ACOG to participate in the AMA RUC process and advocating for relative value units (RVUs) that reflect the work of gynecologic oncologists. By participating in the survey process in collaboration with other medical specialty societies, the Society was able to advocate for work and practice expense values for CPT codes created for 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).

CMS has proposed to accept the RUC-recommended work RVUs without modification of 6.53 and 3.00, respectively. The RUC did not recommend any practice expense values, as HIPEC services are provided only in the facility setting. Recall that while the codes were effective beginning January of this year, the services were Medicare contractor priced. Now the codes will be valued under the MPFS.

Global Surgical Package Values Back in the Spotlight

After years of studying the concept of the global surgical package and the associated payments, the agency has proposed two changes that will allow the agency to collect information on the resources involved in providing global surgical services and the follow-up visits.

First, CMS has proposed to “broaden the applicability of the transfer of care modifiers” and require that practitioners use the existing modifiers for all 90-day global surgical procedures when a practitioner other than the one performing the procedure is expected to provide the pre- and post- operative portions of the service. The modifiers are 54 (surgical care only), 55 (post-operative management only), and 56 (preoperative management only).

Additionally, CMS has proposed a new HCPCS code, GPOC1 that is to be used when a practitioner provides post-operative care to a Medicare beneficiary when the practitioner did NOT perform the surgical procedure. The code was created by the agency to capture the resources provided to a surgical patient post-operatively, despite the absence of a formal transfer of care. The code may only be reported with an office E/M service for new or established patients. Also, GPOC1 may only be billed once during the 90-day global period because the agency “believes the practitioner would only have additional resources costs up the first visit following the procedure.” The proposed work RVU is 0.16.

Telehealth Updates

After extensive efforts by the AMA CPT Editorial Panel to create and the AMA RUC to value E/M codes specifically for the provision of telehealth visits, the agency has proposed NOT to value and pay for the new telehealth E/M codes. The agency stated that the telehealth E/M codes are duplicative of the current set of E/M codes, and therefore, Medicare will continue to pay for telehealth services using place of service indicators and modifiers.

CMS will modify the definition of an interactive telecommunications system. Beginning January 1, 2025, an interactive telecommunications system may include two-way, real-time audio-only 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 may not be capable or may not consent to the use of video technology.

CMS is proposing to permanently adopt a 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 is also proposing to continue the policy that allows teaching physicians to have a virtual presence for services provided by residents in teaching settings through December 31, 2025.