CMS Finalizes 2025 Payment Rules

On November 1, 2024, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2025 Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (OPPS)/Ambulatory Surgical Center (ASC) proposed regulations. Unless otherwise noted, the regulations are effective on January 1, 2025. 

CMS did not explicitly propose extending provisional approval for audiology-specific CPT codes on the telehealth services list in its final CY2025 rulemaking. The Agency provided clarification in the final rule that any CPT codes currently granted provisional approval for telehealth will remain on the telehealth services list through at least 2025. However, CMS emphasized that provisional services, such as those for audiology, will not be permanently added to the telehealth services list until a comprehensive analysis of their effectiveness is completed. CMS has previously stated that this evaluation will be conducted independently of the rulemaking process.  The list of telehealth services codes for CY2025 is available on the CMS site.

Medicare is finalizing a 2.83 percent cut for MPFS services in CY 2025. Medicare payments currently do not keep up with the rising costs of inflation and running a practice. An additional cut for 2025 will further harm already overburdened practices. 

CY 2025 MPFS Key Takeaways for Audiology:   

Payments Decline

The Academy will continue to urge Congress to reverse the 2.83 percent cut to Medicare physician reimbursement announced in the 2025 fee schedule. This cut is based on a proposed 2025 conversion factor (CF) of $32.3465 from the current CY 2024 conversion factor of $33.2875. This is the fifth year in a row that the conversion factor is facing a cut. 

View the CY 2025 vs CY 2024 audiology services payment table

The CF update is primarily based on three factors:

• A statutory 0 percent update scheduled for the Physician Fee Schedule (PFS) in CY 2025
• A 0.02 percent positive budget neutrality adjustment
• The expiration of funding patches passed by Congress through the Consolidated Appropriations Act of 2023 and the Consolidated Appropriations Act of 2024, which partially mitigated cuts to the CF for CY 2023 and CY 2024 resource-based relative value scale and anesthesia CFs.

We support a bipartisan bill recently introduced in Congress, the Medicare Patient Access and Practice Stabilization Act of 2024, which aims to eliminate the 2.8 percent conversion factor cut and provide an approximate +1.80 percent update. We urge Congress to include this bill in an end-of-year legislative package during the post-election lame duck session.

CMS Proposes to End COVID-19 Era Telehealth Flexibilities

CMS plans to end COVID-19 telehealth flexibilities after CY 2024, reinstating pre-COVID limits on geography, service sites, and practitioner types unless Congress acts. CMS will retain virtual supervision for auxiliary personnel and temporarily extend it for teaching physicians overseeing residents. Congress is debating a potential two-year extension, and our societies are actively advocating for continued telehealth access. 

Services Addressing Health-Related Social Needs (Community Health Integration Services, Social Determinants of Health Risk Assessment, and Principal Illness Navigation Services)  

Inthe CY 2025 PFS proposed rule, CMS issued a broad request for information on the new Community Health Integration (CHI) services, Principal Illness Navigation (PIN) services, and Social Determinants of Health (SDOH) Risk Assessment, seeking input on policy refinements for future rulemaking. They requested insights on other factors, including auxiliary personnel types (e.g., Academy-supported roles like audiologists and audiology assistants) and additional certification or training requirements not fully addressed in current coding and payment structures. CMS received extensive comments, which may inform future rule making.

Quality Issues

There are no changes in the Quality Payment Program (QPP) eligibility criteria. Eligible clinicians must:

• Bill more than $90,000 for Medicare Part B covered professional services
• See more than 200 Medicare Part B patients
• Provide more than 200 covered professional services to Medicare Part B patients

To determine if you are an eligible clinician, see the QPP Participation Status Tool. For additional information on QPP and Audiology Quality Measures view the overview.

CY 2025 Hospital-Based Outpatient Department (HOPD)/ASC Rule   

Hospital and ASC Payments Increase

For CY 2025, CMS is increasing payment rates under the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC) Payment Systems by 2.9 percent. This increase is based on a hospital market basket percentage increase of 3.4 percent reduced by a productivity adjustment of 0.5 percentage point. In continuation of an existing policy, hospitals and ASCs that fail to meet their respective quality reporting program requirements are subject to a 2.0 percent reduction in the conversion factor for CY 2025.

View the CY 2025 OPPS rule overview.

Quality

A number of proposals have been made to update and refine facility quality reporting programs. The Academy is continuing to review and determine the feasibility and associated administrative burden of some proposals.

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Below are key MPFS resources:

• Final Rule Text
• CMS Press Release
• CMS Fact Sheet
• CMS QPP Resource Library

Below are key HOPD resources:

• Final Rule Text
• CMS Press Release
• CMS Fact Sheet