New CMS Proposed Rule for CY 2025 Offers Changes to Medicare Payments and Emergency Department Practices
By Courtney Zydron, MD, MBA
VACEP Secretary & President, Williamsburg Emergency Physicians Inc.
What’s the issue? This month, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule for the calendar year 2025 Medicare Physician Fee Schedule (MPFS) or Physician Fee Schedule (PFS).
This rule offers several changes to Medicare payments under the PFS and other Medicare Part B issues, effective on or after the start of the new year.
The rule is subject to a 60-day public comment period, which ends on September 9, 2024. CMS is expected to issue the final rule in early to mid-November.
Zydron
What does this mean for Emergency Physicians? Emergency department providers could face several challenges and opportunities due to the changes put forward:
Reimbursement Reductions: For 2025, the proposed Conversion Factor (CF) proposed by CMS is $32.3562, a 2.8% decrease from the 2024 rates. Despite this reduction, changes in Relative Value Unit (RVUs) are expected to balance out the impact on Emergency Medicine, making it net neutral.
In 2024, the CF was adjusted from $32.7442 to $33.2875 mid-year, which reduced the overall cut from -3.37% to -2.04%. ACEP advocacy efforts at the federal level played a role in mitigating the overall impact to emergency departments.
Behavioral Health Services: CMS is proposing new codes to enhance mental health care integration in emergency settings. This includes an add-on G-code for safety planning interventions performed by the billing practitioner, and a monthly billing code that bundles four follow-up calls after discharge from the emergency department for a crisis encounter.
If approved, these new codes could provide additional revenue for services already performed and it will be important to monitor how commercial payors handle reimbursement. Emergency physicians should monitor the Final Report paying special attention to new behavioral health codes and implement processes to capture revenue for care, including for crisis case management, safety and planning.
Opioid Treatment Programs: Among several changes, CMS is proposing to establish payment with an add-on code for a nalmefene hydrochloride nasal spray product (Opvee®), which is indicated for emergency treatment. Emergency physicians should monitor hospital formulary for this new medication.
Telehealth Flexibilities: For practices utilizing telehealth, CMS aims to continue payment for audio-only services for certain assessments, providing flexibility in patient care when video communication isn't feasible. Emergency physicians will need to update documentation practices that may require additional training to comply with these new telehealth codes. Physicians should continue to keep an eye on the changing landscape for opportunities to implement telehealth into practice.
Looking ahead:
Read up on the changes, and reach out to your elected representatives in D.C. to share the potential impact of the proposed CF on providers’ ability to perform services.
Share your story with VACEP. Our leadership team is here and wants to hear your stories on possible payor, business and care issues. We take your stories to support our advocacy work here in Virginia and at the national level as active members of ACEP.
A final word: As the payer landscape evolves for next year, emergency physicians must stay informed about regulatory changes and adapt accordingly.
