APMA Comments on CY2025 MPFS/QPP

Last week, APMA submitted comments in response to CMS’s Medicare and Medicaid Programs: CY 2025 Payment Policies under the Physician Fee Schedule (PFS) and Other Changes to Part B Payment, etc. APMA’s extensive comments focused on the following concerns, among others:

Medicare Physician Fee Schedule (MPFS) Conversion Factor

APMA is urging CMS to pursue opportunities to mitigate the impact of the proposed conversion factor reductions for 2025, including working with Congress to enact a legislative remedy. As we have previously, we further urge CMS to engage with Congress and stakeholders to develop and enact real reform to the PFS that ensures physicians can consistently rely on sustainable payments over the long term.

Telehealth Services

APMA supported CMS’s proposals to:

• continue suspending frequency limitations for subsequent hospital care services (CPT 99231–99233), subsequent nursing facility visits (CPT 99307–99310), and critical care consultations (G0508 and G0509) furnished via telehealth through CY 2025.
• continue to permit distant site practitioners to use their currently enrolled practice location instead of their home addresses when providing telehealth services from their home through CY 2025.
• continue to define direct supervision to permit the presence and “immediate availability” of the supervising practitioner through real-time audio and visual interactive telecommunications through December 31, 2025.

APMA also supported CMS’s proposal to revise the regulations to state that an interactive telecommunications system may also include two-way, real-time audio-only communication technology for 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 as defined as multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication, but the patient is not capable of, or does not consent to, the use of video technology.

Proposals Related to the CY 2025 Quality Payment Program

For 2025, CMS has introduced six new MIPS Value Pathways (MVPs). CMS acknowledged that its existing portfolio of quality and cost measures may not be applicable to all specialties and/or subspecialties. While none of the new or existing MVPs are relevant to podiatrists, APMA is aware of a potential MVP related to podiatric practice and is providing input on the draft MVP that has been created. APMA asked that CMS take any feedback we may provide into account, especially as it relates to the practice of podiatric medicine and surgery and the feasibility and meaningfulness of proposed measures/activities.

APMA also offered support on the following provisions:

• CMS’s proposal to maintain the 75-point performance threshold for the CY 2025 performance period/2027 MIPS payment year.
• CMS’s idea to allow clinicians the ability to request reweighting of a category when data are inaccessible and unable to be submitted due to reasons outside control of a clinician who delegated data submission to a third-party intermediary (e.g., registry), and that process to request reweighting a category not be overly burdensome for clinicians.

Read the comment letter at www.apma.org/comments. Follow APMA Weekly Focus for updates. If you have questions or concerns, contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.