The Centers for Medicare and Medicaid Services (CMS) has issued its proposal for payments in 2025 under the Physician Fee Schedule (PFS), and it contains an across-the-board 2.8% cut from the current 2024 payment rate. This reduction in payments continues a trend that has seen the Medicare fee schedule reduced nearly 10% over the past 10 years. Last year’s proposed rule (for 2024) contained a 3.36% cut that ended up being a 1.77% cut after Congressional intervention in March, and it is possible that similar action will occur again. The Conversion Factor (CF) in the 2025 Proposed Rule is $32.3562, compared with the $33.2875 currently in use.

The published CMS estimates indicate that most of radiology will be minimally impacted (0%) by the PFS rule, but interventional radiology would see a 2% decrease. However, those calculations do not take into account the Congressional adjustment to the 2024 fee schedule. Our estimate of the actual impact is as follows:

Some Positive News

CMS has proposed that CT Colonography (CTC) would become a covered service for Medicare beginning in 2025. The American College of Radiology (ACR) reports that, “CMS is using statutory authority under the Balanced Budget Act of 1997 for the Secretary to add additional colorectal cancer screening tests and procedures to its definition of screening tests to propose coverage of CTC for Medicare beneficiaries. The rule points out that the U.S. Preventative [sic] Services Task Force (USPSTF) included CTC as a CRC screening method in their June 2016 revised Final Recommendation Statement and again in its May 2021 guideline update.” At the same time, the proposed rule would remove coverage of the double-contrast barium enema, which has mostly been replaced by CTC for colorectal cancer screening.

Direct supervision of certain procedures will continue to be allowed via two-way audio/video communications technology through December 31, 2025. This has been a temporary modification of Medicare rules since 2020, but CMS has failed to make it permanent as they continue to evaluate additional information regarding potential patient safety and quality of care concerns.

Quality Payment Program

In addition to fee schedule changes, the Medicare PFS covers rules that govern the Quality Payment Program (QPP). Radiology practices often participate in the QPP through the Merit-based Incentive Payment System (MIPS). Changes in MIPS scoring for 2025 could have a positive effect for radiology practices.

MIPS Value Pathways (MVP) have not been available to radiology due to a lack of applicable measure sets. “CMS proposes to develop MVPs based on existing Specialty Measure Sets, which would act as a bridge until new measures are available to support the creation of individual MVPs [for radiology]”, according to the ACR.

Under current MIPS rules, there is a cap of seven (7) points on any Quality Category measure that is part of a specialty, such as radiology, with a limited number of measures available for use. CMS is proposing to remove that cap, which means that such measures would receive the full ten (10) points. Diagnostic radiology measures 360, 364, 405, and 406 would be included in this provision.  

Measure #436, Radiation Consideration for Adult CT – Utilization of Dose Lowering Techniques, was previously finalized for removal in 2025, to be replaced by Measure #494, Excessive Radiation Dose or Inadequate Image Quality for Diagnostic CT in Adults.

The Improvement Activities Category has had two levels of measures, medium-weight and high-weight, with the goal of reaching 40 points by submitting from 2 to 4 activities. The proposed rule would eliminate the weighting system, as follows:

• Small practices, non-patient facing, and rural/health professional shortage practices would attest to one (1) activity. This would include many radiologists.
• All other practices would attest to two (2) activities.
• Practices reporting under MVPs would attest to one (1) activity.

Many aspects of the MIPS rules will remain unchanged for 2025, including:

• The MIPS Performance Threshold will remain at 75 points. It had originally been scheduled to move up to 82 points in 2024 and beyond.
• The 75% data completeness criteria will be maintained through the 2028 performance year.
• For practices where performance categories are not reweighted, the category weights remain at: 
  • Quality – 30%, 
  • Improvement Activities – 15%
  • Cost – 30%
  • Promoting Interoperability – 25%
• For practices where Promoting Interoperability and Cost are not a factor, the standard reweighting will be 85% Quality and 15% Improvement Activities (or 50% each for Small Practices).
• The Small Practice bonus will be retained at 6 points in the Quality Category.

Conclusion

The Proposed Rule is usually a pretty good indicator of what the Final Rule will contain when it is issued later in the year. The CF typically changes slightly due to final calculations being applied, but there should be no significant difference. Although many had hoped for legislative correction such as H.R. 2474 to improve the MPFS rate-setting methodology, it does not appear to be likely in 2024. As mentioned above, the Consolidated Appropriations Act, 2024 provided some relief for part of the current year and any hope of avoiding the 2.8% cut will likely come in a similar fashion for 2025.

We will provide our analysis of the Final Rule when it is issued. Subscribe to this blog for all the latest information that affects your radiology practice’s reimbursement.

Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.

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