CMS' Proposed 2025 Medicare Physician Fee Schedule

As 2025 approaches, CMS is seeking feedback on proposed code adjustments and additions that would impact RPM, behavioral health services, and primary care billing.

CMS’s goal is to create a more equitable healthcare system, particularly in terms of accessibility, quality, empowerment, innovation, and affordability for every Medicare beneficiary. To this end, CMS has proposed new codes, definitions, and reporting requirements aimed at expanding patient access to care and simplifying the billing process.

Two doctors discuss the proposed 2025 physician Medicare schedule

These proposed updates could lead to significant changes in how some practices provide care and receive reimbursement. In this article, we highlight and explain key elements of the proposed 2025 PFS, especially those related to RPM and telehealth, to help you better understand their implications for your practice.

Advanced Primary Care Management Services (APCM)

Accessible and effective primary care is a cornerstone of good health. For this reason, the Department of Health and Human Services is committed to supporting and improving primary care delivery. The proposed billing changes for 2025 include three new HCPCS G-codes for Advanced Primary Care Management (APCM) services.

The goal is to simplify the process for healthcare providers to receive payment for delivering high-quality primary care and to reduce their administrative burden.

The three new codes would be grouped to incorporate existing APCM delivery services, divided into three levels that consider the number of chronic conditions and patients’ Medicare Beneficiary status. These levels are labeled as Principal Care Management, Transitional Care Management, and Chronic Care Management. By grouping advanced primary care services under these umbrella codes, relevant care can be provided and billed more easily.

With a proposed start date of January 1, 2025, healthcare practitioners would be able to bill for APCM services as long as they are the sole provider of the patient’s primary care needs. To receive payment, there is a requirement for appropriate performance measurement, which can be fulfilled using the Value in Primary Care MIPS Value Pathway (MVP).

Medicare Payment for Digital Mental Health Treatment Devices

As part of its Behavioral Health Strategy, CMS is proposing new practices to expand behavioral health treatment and support those who provide it. This includes new codes for digital mental health treatment options, some of which are specifically for use by mental health specialists.

To improve access to behavioral health services, CMS proposes Medicare coverage for digital devices used in mental health treatment. These three new HCPCS codes include a monitoring requirement to track how digital devices are utilized within the larger context of patients’ ongoing behavioral health care plans.

Additionally, six new G-codes are proposed for practitioners who are legally limited to the diagnosis and treatment of mental illnesses. This group includes professionals such as Clinical Psychologists, Mental Health Counselors, Clinical Social Workers, and Marriage and Family Therapists. These codes are designed to be similar to those used by medical practitioners, facilitating better integration of behavioral health with other primary care services, thereby improving access to treatment and providing comprehensive support for patients.

Supervision Policy for Physical Therapists (PTs) and Occupational Therapists (OTs) in Private Practice

This proposed rule change introduces more flexibility regarding the mandatory supervision of assistants (PTAs and OTAs) by allowing for ‘general supervision’ while assistants provide care, meaning the PT or OT need not be physically present. This change is especially beneficial for patients in rural and underserved communities who face challenges accessing services.

A Change to the Definition of Direct Supervision

Previously, doctors providing ‘direct supervision’ for certain services had to be physically present. CMS is now proposing a change in the definition, allowing doctors to supervise remotely using digital means.

Care Coordination Services in RHCs and FQHCs

In the interest of more accurate billing systems, CMS is proposing changes in how RHCs and FQHCs report and receive payment for care. Instead of using a single billing code, they would now be required to report each service with individual codes. This change would also allow for the use of add-on codes for relevant services.

Advanced Primary Care Management (APCM) codes would also be available for use by RHCs and FQHCs offering these services. Payments for these services would be in addition to the existing AIR and PPS.

CoachCare Remote Patient Monitoring

CoachCare is your source for everything RPM, including devices, effective monitoring, software updates, and more. We are dedicated to providing you with accurate, up-to-date information on related CPT codes and how they impact your practice. Our ongoing efforts aim to improve treatment access for patients and empower medical professionals to provide well-informed, high-quality care.