CMS Proposes Calendar Year 2025 Payment Rules

On July 10, 2024, the Centers for Medicare and Medicaid Services (CMS) released the proposed calendar year (CY) 2025 Medicare Physician Fee Schedule (MPFS) and CY 2025 Hospital Outpatient Prospective Payment System (OPPS) rules. Once final, the rules would take effect January 1, 2025.

MPFS High-Level Takeaways 

• Payments decline: The proposed CY 2025 conversion factor (CF) is $32.3562, a decrease of approximately 2.80 percent from the final 2024 CF of $33.2875. The CF has continued to decrease over consecutive years, and only congressional action can mitigate this cut. The Academy continues to work closely with other health-care provider stakeholders to urge Congress to address these unsustainable reimbursement cuts.

• Continued coverage of telemedicine: In this proposed rulemaking, CMS chose not to make any current provisional telemedicine services permanent. However, CMS acknowledges that it has received numerous requests for a permanent designation for speech therapy and audiology services. CMS stated it will undertake a comprehensive review independent of this proposed rulemaking.

Quality Payment Program (QPP) Provisions

• CMS does not propose to add or remove any measures from the audiology specialty measures set.
• CMS does propose to add pediatric audiology codes for inclusion under the measure of addressing documentation of current medications in the medical record, in an effort to remove age restrictions currently associated with the measure.
• CMS proposes to maintain the 75 percent data completeness criteria through the 2028 performance period.

The Academy has prepared a chart of proposed 2025 MPFS payment values for audiology codes, available here.

The Academy will further review this comprehensive proposed rule for changes that would affect the provision of audiology services. We will post additional information as it becomes available. CMS is accepting comments on the proposed rule until September 9, 2024.

OPPS High-Level Takeaways

• CMS proposes updating OPPS payment rates for 2025 by 2.6 percent for hospitals that meet applicable quality reporting requirements 
• All but one audiology code would receive a positive payment update under OPPS in 2025 (see tables under resources listed below)

Resources

• Audiology MPFS Proposed CY 2025 Table Based on July 10, 2024 Proposed Rule Release
• CMS Fact Sheet: MPFS Proposed Rule for 2025   
• Audiology OPPS Proposed CY 2025 Tables Based on July 10, 2024 Proposed Rule Publication
• CMS Fact Sheet: OPPS Proposed Rule for CY 2025  
• Full Text of Proposed Rules