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The Centers for Medicare and Medicaid Services (CMS) released the proposed payment regulations for calendar year 2025. Key among these is a proposed 2.8% cut for physician service.  

Our societies will urge Congress to reverse these unacceptable cuts - and you can help by pushing Congress to adopt lasting changes that tie physician payments to the Medicare Economic Index.

Six key takeaways for GI: 

• Physician payments decline: The proposed 2.8% cut for physician service in CY 2025 is based on a conversion factor of $32.36, down from the current CY 2024 conversion factor of $33.29. 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 physician practices.
  

• COVID-19 era telehealth flexibilities end: Absent Congressional action, CMS is proposing that the statutory restrictions on geography, site of service, and practitioner type that existed prior to the COVID-19 PHE will go back into effect beginning Jan. 1, 2025. Current COVID-19 telehealth flexibilities will remain in place until the end of CY 2024.  
  

• Telemedicine office visit codes: CMS proposed not to accept 16 new codes the American Medical Association (AMA) CPT Editorial Panel created to describe telemedicine office visit services (9X075-9X090). CMS believes the currently available office visit codes (99202-99205, 99212-99215) with appropriate modifiers adequately identify telemedicine for the Medicare program. This is good news as it will eliminate the need for physicians to learn how to use and report a new family of CPT codes for telemedicine services and payment for telemedicine services will remain the same as in-person visits. CMS does propose to accept 9X091 with the RUC recommended value of 0.30 work RVUs and it proposes to delete HCPCS code G2012, (Brief communication technology-based service, e.g. virtual check-in), which describes a very similar service to 9X091.
  

• Expanded reporting of office/outpatient (O/O) Evaluation and Management (E/M) visit complexity add-on code G2211: CMS is proposing to allow payment for G2211 when the O/O E/M base code is reported by the same practitioner on the same day as an annual wellness visit (AWV), vaccine administration, or any Medicare Part B preventive service furnished in the office or outpatient setting. The GI Societies will advocate for CMS to provide additional clarity on how our members should use this code.
  

• Expanded colorectal cancer screening: CMS is planning updates to covered colorectal cancer (CRC) screenings that align with the latest evidence-based guidelines. CMS proposes adding coverage of computed tomography (CT) colonography, while removing coverage of barium enema. CMS is also proposing to expand their “complete CRC screening” approach to include either a Medicare-covered blood-based biomarker test or non-invasive stool-based test, and that a follow-on colonoscopy after a positive result would not incur beneficiary cost-sharing. This improves CRC screening access by encouraging patients to be screened without the fear of a surprise bill.  
  

• Changes to Quality Payment Program: CMS is proposing a Gastroenterology Care Merit-based Incentive Payment System (MIPS) Value Pathway (or MVP) for use beginning with the 2025 performance period. The proposed MVP includes 11 MIPS quality measures and 3 QCDR measures within the quality performance category, which are specific to gastroenterology. Currently, MVP reporting is a voluntary alternative that CMS hopes will reduce administrative burden. Our societies previously encouraged CMS to start with a narrowly focused GI MVP addressing a singular clinical condition, specifically colorectal cancer prevention. The proposed MVP includes a broad set of GI-related measures related to colonoscopy, hepatitis and inflammatory bowel disease.
  

CMS also proposes removing the Age-Appropriate Screening Colonoscopy measure from the gastroenterology          specialty measure set for MIPS. The GI societies previously conveyed to CMS this measure should continue to be available for clinician reporting through MIPS.

Key CY 2025 HOPD/ASC takeaways for GI:  

• Hospital and ASC payments increase: CMS proposes updating OPPS and ASC payment rates for hospitals that meet applicable quality reporting requirements by 2.6%. This update is based on the projected hospital market basket percentage increase of 3.0%, reduced by a 0.4 percentage point productivity adjustment.
  

• Changes to colonoscopy cost sharing: Like the proposed changes for physicians, CMS proposes to codify its definition of “CRC screening tests” to include a follow-on screening colonoscopy after a positive blood-based colorectal cancer (CRC) screening test. This change aims to eliminate patient cost-sharing for facility fees, ultimately improving access to care and cancer prevention. 
  

• Quality: A number of proposals have been made to update and refine facility quality reporting programs. Our societies will comment on the feasibility and associated administrative burden of some proposals.
  

Resources 

CMS Medicare Physician Fee Schedule Proposed Rule and Fact Sheets

2025 MPFS Proposed Rule GI Payment Changes

CMS Hospital Outpatient and ASC Proposed Rule and Fact Sheets