Absent any last-minute Congressional action, physicians will suffer a 2.83% fee schedule reduction for 2025. This is slightly more of a cut than had been predicted in the Medicare Physician Fee Schedule (MPFS) Proposed Rule that was issued in July. As we reported in our analysis of the Proposed Rule, this reduction in payments continues a trend that has seen the Medicare fee schedule reduced by nearly 10% over the past 10 years.

The Conversion Factor (CF) in the 2025 Final Rule is $32.3465, compared with $33.2875 that has been in effect for most of 2024. As required by law, CMS rolled back a 2.93% temporary upward adjustment enacted by the Consolidated Appropriations Act, 2024 (CAA), and then applied a positive 0.02% budget neutrality factor to arrive at the final $32.3465 amount.

The published CMS estimates indicate that most of radiology will be minimally impacted (0%) by the MPFS, but interventional radiology will see a 2% decrease. However, our analysis of the Proposed Rule projected greater impacts when the effect of removing the CAA adjustment is factored in. See Table 1.

Table 1

Positive Changes for Radiology Confirmed

CMS has made CT Colonography (CTC) a covered service for Medicare beneficiaries beginning in 2025 and ended coverage of the double-contrast barium enema, which has mostly been replaced by CTC for colorectal cancer screening. CT Colonography Screening (code 74263) will be reimbursed at the national level of $108.68 (3.36 RVU) for the professional component, which is a slight upgrade from the Proposed Rule value of 3.22 RVU. However, the procedure is subject to the rule whereby reimbursement for the technical component is limited to the lesser of the MPFS or the hospital outpatient fee schedule (OPPS). That rule reduces the global reimbursement from $699.98 to $350.40 for global billing. The American College of Radiology (ACR) applauds the decision to allow coverage of the procedure but takes exception to the OPPS cap limitation on reimbursement. The actual fee in each locality will be determined by adjusting for the Geographic Practice Cost Index (GPCI).

New codes will be available to report MRI Safety procedures, as follows in Table 2.

Table 2

G = Global; PC = Professional Component

The ACR explains that 76014 and 76015 are technical component codes that do not include any physician work value, but they would be available in the imaging center using global billing. We will cover the use of these new codes in more detail in our annual coding update.

Direct supervision of certain procedures will continue to be allowed via two-way audio/video communications technology for another year, 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

The MPFS includes rules that govern the Quality Payment Program (QPP). Radiology practices often participate in the QPP through the Merit-based Incentive Payment System (MIPS), and for 2025, there are seven new Quality Category measures, 10 removed measures, and 66 measures that have been changed.

The MIPS Quality Performance Category scoring has been modified for 2025, which could have a positive effect for radiology practices. Under current MIPS rules, there is a cap of seven 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 has made a change for 2025 to remove that cap, which means that such measures will receive the full 10 points. Diagnostic radiology measures 360, 364, 405, and 406 are 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 . Unfortunately, Measure #494 may not be as useful due to the need for practices to have additional software that will enable them to gather and report the required data.

Another change that could help radiologists is in the Improvement Activities Category, which has had two levels of measures, medium-weight and high-weight, with the goal of reaching 40 points by submitting from two to four activities.

Beginning in 2025, CMS has simplified the weighting system, as follows:

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

MIPS Value Pathways (MVPs) have not been available to radiology due to a lack of applicable measure sets. The Proposed Rule asked for input from interested parties on how to improve the MVP option, and the Final Rule includes a “plan to use the feedback submitted for consideration in future rulemaking,” according to the ACR.

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 Quality Category bonus will be retained at 6 points.

Is the Final Rule Really Final?

We have been following H.R. 2474 since it was introduced on April 3, 2024. This bill would improve the MPFS rate-setting methodology, but it has not yet been acted upon by the House even though it has 170 cosponsors. Another bill, H.R. 10073, the Medicare Patient Access and Practice Stabilization Act of 2024, was introduced on October 29 th that would again temporarily provide an increase in the Medicare fee schedule for 2025. The American College of Radiology (ACR) urges all radiologists to contact their representatives to support this and other pending legislation when Congress returns to session on November 12, 2024.

We will continue to monitor changes in the Medicare fee schedule.

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

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