As Congress continues negotiations ahead of the March 14 government funding deadline, ACG wants to remind members about the key payment policies that could impact your practice in 2025.
ACG Continues to Urge Congress to Reverse Medicare Cuts – 2025 ‘Doc Fix’ Introduced
The CY 2025 Medicare CF is $32.3464, reflecting a 2.83% decrease from 2024. This marks the fifth consecutive year of declines in the Medicare CF. The payment reduction is occurring within a broader context of increasing practice costs. ACG is acutely aware that these annual cuts are unsustainable and is collaborating with the AMA and other national stakeholders to encourage Congress to reverse the cut.
Bipartisan Payment Fix Introduced
On January 31, a bipartisan group of Congressional members reintroduced the Medicare Patient Access and Practice Stabilization Act to address the 2.83% cut to the Medicare CF that went into effect on January 1, 2025.
- The legislation proposes a 6.62% bump to the physician fee schedule (PFS).
- This would eliminate the current 2.83% reduction and provide an additional 2% payment increase.
- This legislation is effective from April 1, 2025, until the end of the year. It is NOT retroactive, meaning it will not affect claims from the first three months of the year.
Government funding runs out on March 14, and Congress must act to fund the government through the remainder of the fiscal year. While packaging the Medicare payment fix into the expected spending package to continue funding the government beyond mid-March is the most likely vehicle, a path forward remains unclear.
ACG is working with our partners to urge Congress to advance this bill – you can help!
Telehealth Flexibilities Set to Expire on March 31st; Advocacy Efforts to Extend Are Ongoing
Certain telemedicine flexibilities established during the COVID-19 pandemic were extended through March 31, 2025. These flexibilities include:
- Allowing services to be provided in the patient’s home (flexibilities on geographic restrictions).
- Allowing the provision of audio-only services.
- Expanded definition of practitioner allowed to provide telehealth services.
- Extending telehealth services for federally qualified health centers (FQHCs) and rural health clinics (RHCs).
- Delay of in-person requirement for mental health services until April 1.
- Telehealth fulfills the face-to-face requirement for hospice recertification.
ACG and other telehealth advocates are working to get Congress to extend these flexibilities beyond March 2025.
CMS Declines to Recognize New Telemedicine Evaluation/Management (E/M) CPT© Codes
The CY 2025 CPT book includes 17 new telemedicine office visit codes. These codes include 98000-98003 for audiovisual telemedicine visits (new patients), 98004-98007 (established patients), 98008-98015 for audio-only telemedicine visits (new and established patients), and 98016 for a virtual check-in code. Audio-only telephone codes 99441-99443 were deleted for 2025.
However, in the CY 2025 Medicare PFS, CMS announced it would not recognize 16 of the 17 new codes, 98000-98016. However, CMS will recognize 98016, which was previously reported by G2012 and which CMS is deleting due to the creation of the new CPT code 98016.
Although CMS will not pay separately for the new telemedicine office visit codes, some commercial payers might choose to recognize them. ACG recommends checking with your payers to better understand their telemedicine policies.
Merit-based Incentive Payment System (MIPS) Reporting Updates
MIPS is the Medicare quality reporting program for physicians and other qualified healthcare professionals that applies solely to your fee-for-service Medicare claims. Through MIPS, eligible clinicians earn bonuses or face penalties on their claims based on their performance in four areas: quality, cost, interoperability, and improvement activities.
Here are some key updates for the MIPS program.
Data Submission is Now Open: The Centers for Medicare & Medicaid Services (CMS) opened data submission for the 2024 performance year of the Quality Payment Program (QPP). Data can be submitted and updated until 8 p.m. ET on March 31, 2025. Your 2024 data will impact your 2026 performance.
2025 Data Reporting Flexibilities for Providers Recovering from Natural Disasters: In January, ACG urged CMS to stand with providers affected by recent natural disasters, and we are pleased to report the agency has granted the very exemption we requested. This ‘Automatic Extreme and Uncontrollable Circumstances’ (EUC) exemption applies to practices located in certain counties in Georgia, North Carolina, or Tennessee recovering from Hurricane Helene, as well as Los Angeles County due to the California wildfires.
CMS says affected providers will be identified automatically, and the exemption will apply to performance years 2024 and 2025 (meaning a neutral payment adjustment for 2026 and 2027). Providers can still submit data for scoring and payment adjustments, if desired, and the exemption does not automatically apply to providers in a group, subgroup, virtual group, or APM. More information is available from CMS here.
2025 MIPS Payment Adjustments in Effect Based on 2023 Performance: In August 2024, each MIPS-eligible clinician received a 2023 MIPS final score and associated payment adjustment factor(s) as part of their 2023 MIPS performance feedback, available on the QPP website. 2025 MIPS payment adjustments, based on each MIPS-eligible clinician’s 2023 MIPS final score, will be applied to payments made for Part B covered professional services payable under the Physician Fee Schedule from January 1 to December 31, 2025.
Payment adjustments are determined by the final score associated with a clinician’s Taxpayer Identification Number (TIN)/National Provider Identifier (NPI) combination. MIPS-eligible clinicians, identified by TIN/NPI combination for the 2023 performance year, will receive a positive, neutral, or negative MIPS payment adjustment in 2025. For 2025, MIPS payment adjustments range from -9% to a maximum positive score of 2.15%.
New Gastroenterology MIPS Value Pathway (MVP) for CY 2025: In 2020, CMS established the MVP as an alternative MIPS participation option. Under the MVVP option, activities and measures are centered around a specialty. This framework intends to streamline participation in a program that has been criticized for being administratively burdensome. In 2025, CMS launched the Gastroenterology MVP. To report an MVP, you must register between April 1, 2025, and December 1, 2025. More details on the Gastroenterology MVP can be found here.
The first month of the second Trump Administration has brought a flurry of executive orders and actions, some affecting healthcare. Rest assured that ACG is engaging with both the new Administration and Congress to ensure that your needs and the patients they serve are addressed.