News November 01, 2024

Broken Medicare System Results in CMS Reducing Physician Payments in 2025

On November 1, 2024, the Centers for Medicare and Medicaid Services (CMS) released its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) and the Quality Payment Program (QPP) final rule. CMS finalized significant cuts to the Anesthesia Conversion Factor that will compound the financial strain that anesthesia groups are already facing. The final rule underscores how the Medicare payment system is broken and in dire need of reform. Since the summer, ASA and other medical specialties have been advocating for Congressional action to stop these cuts and for more comprehensive reforms to take place.

Fee Schedule Provisions:

The 2025 final Anesthesia Conversion Factor (CF) is $20.3178, representing a decrease of 2.20% from the 2024 Anesthesia CF of $20.7739. The 2025 final RBRVS CF is $32.3465. This represents a decrease of 2.83% from the 2024 CF of $33.2875. The change to the PFS conversion factors incorporate the 0.00 percent overall update adjustment factor required by statute, a relatively small estimated positive 0.05% budget neutrality adjustment necessary to account for changes in work relative value units (RVUs) for some services, and the expiration of the temporary 2.93% increase in payment for services furnished from March 9, 2024 through
December 31, 2024. The negative adjustments result in large part from a statutorily mandated budget neutrality adjustment to account for changes in work Relative Value Units (RVUs). This means spending in one year needs to be balanced by reductions. CMS cannot increase or decrease expenditures by more than $20 million without triggering automatic budget neutrality adjustments.

Final Conversion Factors:

	2024 CF	Final 2025 CF	Percent Change
Anesthesia	$20.7739	$20.3178	-2.20%
RBRVS	$33.2875	$32.3465	-2.83%

Source: Table 108 and Table 109, CY 2025 PFS Final Rule, display copy

Specialty Impact on Anesthesia and Pain Medicine

Actual payment rates are impacted by a range of policy changes that are included in the rule related to physician work, practice expense, and malpractice RVUs. Impact by practice will vary based on service mix. Specialty impacts ranged from -2% for Vascular Surgery and Diagnostic Testing Facility, to +4% for Clinical Social Worker. The table below indicates the impact of policies in the rule will have on anesthesiology and interventional pain management. Changes to the Conversion Factors are not reflected in the impact table.

Specialty	Allowed Charges (mil)	Impact of work RVU Changes	Impact of PE RVU Changes	Impact of MP RVU Changes	Combined Impact
Anesthesiology	$1,591	1%	1%	0%	2%
Nurse Anesthetist/ Anesthesiologist Assistant	$1,056	0%	1%	0%	1%
Interventional Pain Management	$839	0%	0%	0%	0%

*Note: Combined Impact may not equal the sum of work, PE and malpractice due to rounding.

Source: Table 110, CY 2025 PFS Final Rule, display copy

Pain Medicine Code Updates

CMS finalized the values of several Fascial Plane Block codes, scoring a significant win for anesthesiologists and pain medicine physicians. Starting January 1, 2025, pain medicine physicians will be able to get paid by Medicare for providing thoracic (64466, 64467, 64468, 64469) and lower extremity (64473, 64474) fascial plane block services reported with these new Category I CPT codes. These new thoracic and lower extremity fascial plane block services expand on this existing transversus abdominis plane (TAP) block code family in CPT (64486 – 64489). For CY 2025, CMS finalized the following work RVUs for the fascial plane block codes. The table below reflects CMS’s proposed work RVUs for the fascial plane block codes.

Code	Descriptor	Finalized 2025 wRVU
64466	Thoracic fascial plane block, unilateral; by injection(s), including imaging guidance, when performed	1.50
64467	Thoracic fascial plane block, unilateral; by continuous infusion(s), including imaging guidance, when performed	1.74
64468	Thoracic fascial plane block, bilateral; by injection(s), including imaging guidance, when performed	1.67
64469	Thoracic fascial plane block, bilateral; by continuous infusion(s), including imaging guidance, when performed	1.83
64473	Lower extremity fascial plane block, unilateral; by injection(s), including imaging guidance, when performed	1.34
64474	Lower extremity fascial plane block, unilateral; by continuous infusion(s), including imaging guidance, when performed	1.67
64486	Transversus abdominis plane (TAP) block (abdominal plane block, rectus sheath block) unilateral; by injection(s) (includes imaging guidance, when performed)	1.20
64487	Transversus abdominis plane (TAP) block (abdominal plane block, rectus sheath block) unilateral; by continuous infusion(s) (includes imaging guidance, when performed)	1.39
64488	Transversus abdominis plane (TAP) block (abdominal plane block, rectus sheath block) bilateral; by injections (includes imaging guidance, when performed)	1.40
64489	Transversus abdominis plane (TAP) block (abdominal plane block, rectus sheath block) bilateral; by continuous infusions (includes imaging guidance, when performed)	1.75

Please contact [email protected] with any questions related to the Medicare Physician Fee Schedule.

Advocacy in the Lame Duck Session:

ASA is committed to advocating for changes to the broken Medicare payment system and ensure that anesthesiologists and pain medicine physicians are paid fairly. ASA supports stopping the January 1, 2025 payment cut and implementing a mandatory inflation adjustment to Medicare payments to allow for the compensation of our physicians and other clinicians to match rising cost of living across the country. Stay tuned for an ASA Congressional Call to Action following Election Day and in anticipation of the Congressional lame-duck session.

Quality Payment Program Provisions:

CMS also released its 2025 Quality Payment Program (QPP) final rule. The rule provides details on how CMS intends for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models, and other features of the QPP during the 2025 performance year.

For the 2025 reporting year:

CMS will maintain the CY 2025 MIPS performance threshold at 75 points. Scoring above 75 points would allow an individual or group a payment bonus while scoring below 75 points would result in a payment penalty in 2027.
CMS finalized the 2025 anesthesia measure set without any changes from 2024.
CMS will maintain the data completeness threshold for the MIPS Quality Performance Category a 75% through the CY 2028 performance period.
CMS is removing the 7-point cap for scoring certain topped out quality measures (defined through annual rulemaking) in specialty sets with limited measures. On the list are four measures within the anesthesia measure set (QID424 Perioperative Temperature Management, QID430 Prevention of Post-Operative Nausea and Vomiting (PONV) - Combination Therapy, 463 Prevention of Post-Operative Vomiting (POV) Combination Therapy (Pediatrics) and 477 Multimodal Pain Management).

Anesthesiologists will continue to have the opportunity to report the Anesthesiology MIPS Value Pathway (MVP) in 2025. CMS believes MVPs alleviate some of the reporting burdens that anesthesiologists and other physicians encounter in the MIPS program. For 2025, CMS did not change any of the quality measures but finalized changes the available improvement activities in the Anesthesia MVP:

CMS added IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B. This IA is being added to all new and previously finalized MVPs.
For consistency with other policy changes, CMS removed the weights associated with the improvement activities contained in this MVP.
CMS removed the IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient's Medical Record

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].

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ASA leaders and staff will review the rule and submit comments by the deadline. Unless otherwise noted, finalized provisions will become effective on January 1, 2025.

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