July 27, 2024
By: Laura Manser, CPC, CDEO, CIRCC, CPMA, CEMC, RCC, Director of Provider Education
Overall Summary of 2025 Medicare Physician Fee Schedule Proposed Rule
- CMS has proposed changes to the Medicare Physician Fee Schedule (MPFS) for 2025, which could have varying impacts on different areas of radiology. For general radiology, nuclear medicine, and radiation oncology, the overall financial impact is expected to remain neutral, with no significant changes in reimbursement. However, interventional radiology might experience a slight decrease of about 2% if the proposed rule is finalized.
- It’s important to note that this assessment does not account for the expiration of the temporary payment increase provided by the Consolidated Appropriations Act of 2024. The proposed conversion factor for 2025 is $32.3562, which is approximately 2.8% lower than the 2024 conversion factor of $33.2875. This reduction could affect overall payments across all radiology services.
Conversion Factor and Impact on Radiology
- Conversion Factor: CMS proposed a conversion factor of $32.3562 for 2025, which is slightly lower than the 2024 rate of $33.2875.
- Impact on Radiology: Overall, CMS expects no change for radiology, nuclear medicine, and radiation oncology, but interventional radiology could see a 2% decrease if the rule is finalized.
Coverage for Colorectal Cancer Screening
- New Coverage: CMS is proposing to cover Computed Tomography Colonography (CTC) for colorectal cancer screening. This test is less invasive and easier on patients compared to traditional colonoscopies.
- Barium Enema Removal: CMS plans to stop covering the barium enema procedure for colorectal cancer screening, as it’s no longer considered the best option.
Technical Component Reimbursement
- CT Colonography: The technical component of CT Colonography might be capped at $106.30, lower than the proposed Medicare Physician Fee Schedule rate of $528. If this is finalized, the lower rate will apply across both hospital and freestanding settings.
Practice Expense Updates
- Price Updates: CMS is proposing updates to the prices of certain supplies and equipment used in radiology, based on new invoices. They are also reviewing how to best update these prices in the future.
New CPT Codes and Procedures
- MRI-Monitored Prostate Treatment: Three new codes were introduced for MRI-monitored ultrasound ablation of the prostate. These codes are expected to have work values of 4.05, 9.80, and 11.50.
- Thyroid Nodule Ablation: Two new codes for thyroid nodule ablation procedures are proposed, with work values of 5.75 and 4.25.
- MR Safety Procedures: Six new codes were added for safety procedures related to MRI for patients with implanted medical devices. These procedures help ensure patient safety during MRI scans.
Global Surgery Payment Accuracy
- Post-Operative Care: CMS is concerned that some post-operative visits included in global surgery payments are not being performed. They propose that doctors use special codes when transferring care during the post-operative period to prevent overpayments.
Supervision Flexibility
- Virtual Supervision: CMS is extending the flexibility to allow doctors to supervise certain procedures via real-time audio and video through 2025. They are considering making this a permanent option for some lower-risk services.
Quality Payment Program (QPP) Updates
CMS is proposing several changes to the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) for the 2025 performance year. For the 2025 performance period, CMS proposes to maintain the 75-point performance threshold. No changes are proposed for the MIPS adjustment.
- Removal of Measure #436: CMS plans to remove Measure #436, which focuses on “Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques,” from the list of available measures. This measure is being removed as it is considered duplicative of the following newly added measure in the Diagnostic Radiology set.
- Addition of Measure #494: A new measure, Measure #494, titled “Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults,” will be added to replace the removed measure. Notably, this new Diagnostic Radiology measure is an eCQM, which means it will not be reportable as a traditional MIPS CQM.
- MIPS Value Pathways (MVPs): CMS is moving towards using MVPs instead of the traditional MIPS program. These pathways are designed to simplify reporting and improve care coordination.
- New Requests for Information: CMS is asking for public feedback on how to improve care in ambulatory specialty settings and how to fully transition to MVPs.
These updates reflect CMS’s ongoing efforts to improve the accuracy and relevance of the measures used in MIPS, ensuring that the program continues to drive quality improvement and care coordination across the healthcare system.
Changes to Radiology-Specific Codes
- Misvalued Services: CMS is reviewing and seeking feedback on several radiology codes to ensure accurate payment. These include codes related to fine needle aspiration biopsies and sacroiliac joint procedures.
Final Notes
- Stakeholder Feedback: CMS is actively seeking feedback from medical professionals and organizations to refine these proposals before finalizing them.
Laura Manser, CPC, CDEO, CIRCC, CPMA, CEMC, RCC, is the Director of Provider Education at PBS Radiology Business Experts. With 24 years of experience in radiology, specializing in professional and hospital coding and auditing, Laura is a valuable resource for physicians and coding teams nationwide. She is dedicated to accurate and compliant medical coding and to developing clinical documentation improvement programs within radiology practices. Laura enjoys educating coders and physicians to enhance coding accuracy and documentation, optimizing revenue. Known for her proactive leadership, strong work ethic, and commitment to excellence, Laura holds multiple coding certifications from AAPC and RBMA.