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However, the proposed rule includes several wins, including adjustments to the rules for the G2211 add-on code and policies to strengthen primary care

Aug. 9, 2024 (ACP) -- The proposed for 2025 was released in mid-July, and although there are several beneficial reforms in the proposed rule, statute requires that the Centers for Medicare & Medicaid Services adjust the conversion factor to ensure overall “budget neutrality” within the fee schedule. Therefore, once again, physician reimbursement rates must be cut -- this time by 2.8 percent.

“We need Congress to step in to stop the payment cut from going into effect,” said Dr. Isaac O. Opole, president of ACP. “ACP has been calling on Congress for the past several years to take long-term action to fix this issue. We need a permanent solution from Congress to fix these payment cuts that repeat year after year. Physician payments under Medicare have not kept pace with inflation, leading to an effective 30 percent payment cut over the last two decades that harms the physician workforce and our patients' access to care.”

However, in a major win for ACP, the agency plans to adjust the rules around the new G2211 add-on code.

“ACP has strongly advocated for changes that make patient visits more comprehensive and reduce confusion around the billing for G2211,” said Dejaih Johnson, ACP manager of regulatory affairs. “CMS's proposal -- to allow G2211 to be billed on the same day as an annual wellness visit, vaccine administration and any Medicare Part B preventive service -- goes a long way in helping recognize the comprehensive nature of these visits and ensuring that physicians are paid for the full scope of services provided.”

Johnson added that several proposals will support the primary care workforce, such as the new enhanced program for Advanced Primary Care Management services. “This program could relieve administrative burdens and more appropriately reimburse physicians caring for patients with complex medical and social needs, helping promote health equity,” she said.

ACP is also encouraged by a request from CMS for information about designing a potential ambulatory specialty care model. “ACP previously proposed a medical neighborhood model as an Advanced Alternative Payment Model proposal that would improve care coordination between specialty practices and the primary care practices that refer patients to them,” Johnson said. “ACP has long expressed the need to increase the engagement of specialists in value-based care, and we look forward to working with CMS to implement and scale the potential model.”

In addition, CMS plans to establish a new “prepaid shared savings” option for accountable care organizations (ACOs) with a history of earning shared savings. “This allows for investments to better serve beneficiaries in underserved communities and to provide more significant financial incentives for ACOs to serve even more beneficiaries from underserved communities via a Health Equity Benchmark Adjustment,” Johnson explained, “which has been associated with increased safety net physician participation.”

CMS also proposes to permanently expand the definition of “telecommunications systems” to cover audio-only telehealth services and more closely align them with policies for audio-video telehealth services. ACP has advocated for this change since the beginning of the COVID-19 pandemic, noting that audio-only telehealth services are essential to improving access to care for specific populations. These populations include low-income patients and those who lack broadband access, have low digital literacy, or do not have access to audio-video technology.

Finally, ACP welcomes plans to establish new payments to physicians and other health care professionals who are assisting patients at high risk for suicide or overdose. The proposed fee schedule includes separate payments for safety planning interventions and post discharge follow-up contacts.

Unfortunately, the proposed fee schedule also includes a 2.8 percent payment cut for 2025. This cut is due to a decrease in the conversion factor used to calculate physician payment rates, which is required by current law to remain “budget-neutral” from year to year.

“Last year, congressional action was able to partially fix the payment cut, but that fix will expire at the end of this calendar year,” Johnson said. “ACP has continued to call on Congress to pass legislation that implements an annual inflation-based physician payment update tied to the Medicare Economic Index and modernizes Medicare's antiquated budget neutrality policies.”

Johnson added that “ACP staff are diligently summarizing this year's proposed rule, and the College intends to submit comments to CMS by the Sept. 9 deadline. Once the agency receives and considers all public submissions, CMS will release the final rule. Any finalized provisions would take effect Jan. 1, 2025.”

Back to the August 9, 2024 issue of ACP Advocate