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The AOA recently submitted comments on the Centers for Medicare & Medicaid Services (CMS) proposed CY2025 Medicare Physician Fee Schedule, which outlines critical changes that will affect physician reimbursement, telehealth services and overall healthcare delivery. Below is an abridged summary of the key points highlighted in the response.
CMS has proposed a conversion factor of $32.3562 for CY2025, representing a 2.77% decrease from the previous year. This reduction is due to the expiration of a temporary 2.93% upward adjustment and other budget neutrality adjustments. The comments state that the AOA is concerned that this reduction will disproportionately affect small and independent practices, which are already struggling to keep up with rising operational costs. Since 2000, physician practice costs have increased by 48%, while payment updates have only risen by 12%, leading to significant financial strain.
CMS proposes to adjust the historical benchmark of accountable care organizations (ACOs) based on the proportion of beneficiaries eligible for Medicare and Medicaid (dual eligibles). The goal is to incentivize practices serving underserved communities to participate in the MSSP. Additionally, CMS introduces a “prepaid shared savings” option for ACOs with a history of shared savings, allowing them to invest in care coordination, infrastructure and enhanced care services. The AOA supports these initiatives, particularly the flexibility for practices to use advanced payments for infrastructure improvements.
CMS has proposed maintaining the Merit-based Incentive Payment System (MIPS) performance threshold at 75 points for 2025, which the AOA supports, given ongoing challenges posed by the COVID-19 pandemic and other disruptions like the Change Healthcare cyberattack. However, the comments express concerns about the CMS proposal to score the most recent MIPS data submission instead of the highest-scoring one, as it could negatively impact physician performance scores. The comments also state the support for new scoring methods for “topped out” measures but urge CMS to apply this policy broadly to help physicians with limited measure choices.
Additional topics discussed in the comment letter include:
This is just a small example of the many topics and comments made in the letter. Be sure to read the full comment letter to learn more about how the AOA is fighting for your interests in shaping health care policy. Our continued engagement with CMS and Congress demonstrates the importance of ensuring that osteopathic physicians are fairly compensated for their work, especially in light of ongoing financial pressures.
This is why we encourage you to join us in these efforts. Visit our advocacy action center today to send an email to your lawmakers, urging them to support legislation that prevents harmful Medicare payment cuts and promotes a long-term solution for sustainable Medicare physician payment. Together, we can protect the future of osteopathic medicine and the patients you serve.