This year's MPFS proposed rule brings a few acute triumphs and at least one significant and painfully recurrent loss for radiologists.
From the Chair of the Commission on Economics
Gregory N. Nicola, MD, FACR
On July 10, 2024, CMS released the 2025 Medicare Physician Fee Schedule (MPFS) proposed rule.
Let’s get the bad news out of the way first. For 2025, CMS estimates an overall impact of the MPFS proposed changes to radiology, nuclear medicine and radiation oncology to be a neutral 0%, while IR would face a 2% decrease in payments. These changes are related to shifts in RVUs specific to radiology codes and reflect the tireless efforts and collective success of our ACR Current Procedural Terminology (CPT®) and AMA/Specialty Society Relative Value Scale Update (RUC) teams. However, despite holding ground relative to our own RVUs, radiologists will be the victims yet again of a decrease in the Conversion Factor (CF), which is proposed to fall to $32.36 compared to this year’s $33.29, a 2.8% decrease. Combined with a 2% sequestration cut and a 4% PAYGO cut that returns on Jan. 1, 2025, absent Congressional intervention, the worst-case scenario would be a cut of over 8%. Appallingly, if the proposed 2.8% decrease to the CF is finalized, the CF will have been cut by 10% over the past five years. This is painful enough before considering that, over the same time, inflation has increased almost 20% as measured by the consumer price index. The ACR continues to advocate for a legislative fix that would tie the MPFS to the Medicare Economic Index (H.R. 2474), but for now the bad news remains.
On the bright side, after 16 years of indefatigable advocacy from the ACR, CMS has finally proposed to reimburse CT colonography for colorectal screening in both the Hospital Outpatient Prospective Payment System (HOPPS) and the MPFS. Coverage for CT colonography would replace coverage for double contrast barium enema as a screening method.
The ACR continues to advocate for a legislative fix that would tie the MPFS to the Medicare Economic Index (H.R. 2427), but for now the bad news remains.
Another win for radiologists in the 2025 rule is a proposed change to the scoring methodology for the Quality category of the Merit-Based Incentive Payment System (MIPS). This decision came following years of the ACR’s economics team educating CMS about the lack of measures available for radiologists to report into MIPS and the subsequent unavoidable and unfair impact on radiologists’ ability to score well in the program. Under the new proposed scoring, specialties with limited number of available measures would no longer be forced to accept a 7-point scoring cap on topped-out measures. Currently, even radiologists who perform perfectly on the quality measures available for their specialty find themselves facing a payment penalty. CMS is proposing to remove the scoring cap on topped out measures for specialties who would be unable to reasonably achieve 75% of available quality achievement points based upon the measures available to them and program requirements. For 2025, CMS is proposing to remove the scoring cap from all the topped-out measures in the current radiology specialty measure set: including measures 360, 364, 405 and 406. The opportunity to score 10 points for these measures is a huge win for radiologists and should put ACR members in a better position to fare well in MIPS. Going forward, CMS proposes an annual review to determine which topped-out measures should be given this scoring adjustment.
Finally, CMS proposed good but potentially temporary news regarding virtual supervision of contrast coverage. The expanded definition of direct supervision to include two-way audio/video communications technology was set to expire at the end of 2024. CMS acknowledges that this policy has expanded access to services and in the absence of evidence that patient safety is compromised by virtual direct supervision, the agency proposes to extend the policy until Dec. 31, 2025, stopping short of making it permanent. For radiology groups that have implemented or are considering remote supervision of contrast, this is an encouraging but unsatisfying proposal.
For more wins and losses in the MPFS, please see the ACR’s initial summary. As always, we will continue to advocate for our members through formal written response to the proposed rule in our comment letter. As we found out this year, sometimes persistence pays off.
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