2025 Proposed MPFS Summary: A Mixed Bag for Family Medicine 

The summary generally concurs with CMS’ assessment of its proposed rule. The agency said the proposal, released July 10, emphasizes whole-person care with measures such as a new advanced primary care management bundle; expanded access to behavioral, preventive and oral health services; and a suite of updates to the Medicare Shared Savings Program and the Quality Payment Program. But that assessment also describes ongoing challenges to Medicare physician payment.

Read the Academy’s full executive summary for details of proposed work and practice expense values for specific codes, and these other key points.

Another Conversion Factor Hit

CMS proposes to decrease the conversion factor (the amount Medicare pays per relative value unit) to $32.35, a drop of 2.8% from the 2024 factor. Taking into account relief that’s expiring — which Congress enacted last year to offset the 2024 decrease — “the AAFP estimates the impact will be a 1.9% decrease in total allowed charges for family physicians,” the summary says. 

“While all providers paid under the fee schedule are subject to the payment decrease attributable to the reduced conversion factor, the impact to family physicians is less severe than the average due to a number of proposals included in the rule that will benefit family practice,” it adds. 

As the AAFP recently told members, the proposed 2025 conversion factor continues a trend of reduced conversion factors; the 2024 conversion factor was about 3.4% less than 2023’s rate. Congress has responded to these reductions the past few years by passing short-term conversion-factor relief. The AAFP continues to press lawmakers for permanent Medicare payment reforms, such as eliminating the budget-neutrality requirement that prevents CMS from improving payment in any area of the fee schedule without cutting it somewhere else.  

E/M Win 

In direct response to AAFP’s advocacy following this year’s implementation of the G2211 add-on code (a significant win for family physicians), the proposed rule would reduce some key restrictions on G2211, including limits on the use of modifier 25. Starting in 2025, G2211 will be payable when modifier 25 is coded to show that certain services were furnished during an evaluation and management encounter, including 

• the Medicare annual wellness visit, 

• vaccine administration or  

• any Medicare Part B preventive services.  

Telehealth and Virtual Care 

As the AAFP requested, CMS includes in its proposed rule “a request for information on a permanent expansion of the list of services under the primary care exception,” the summary says. A flexibility expanded during the COVID-19 public health emergency, the primary care exception allows teaching physicians to directly supervise residents via real-time, interactive audio/visual technology and bill for certain services furnished by residents. The Academy has sought the permanent adoption of the exception’s expanded list of services.

With other pandemic-initiated telehealth flexibilities expiring at the end of 2024, the Academy has continued to urge passage of legislation that would maintain robust options for patient access to primary care, particularly in rural areas. 

Additionally, “CMS intends to conduct a comprehensive analysis of all codes on the Medicare Telehealth Services list before determining which codes should be added on a permanent basis,” the Academy’s summary says.  

Enhanced Care Management

“CMS proposes new bundled payments for advanced primary care teams and notes this is a first step in a multiyear effort toward hybrid payment and accountable care,” the summary says.

Three new codes for advanced primary care management services would incorporate elements of several existing care management and communication technology-based services into a bundle.  

Shared Savings Program 

Proposed changes to Shared Savings Program policies “are directionally consistent with the AAFP’s advocacy to improve value-based care participation opportunities for family physicians, particularly those caring for underserved populations,” the summary says.

CMS is also seeking comments on financial arrangements that could allow for higher risk and potential reward than the current Enhanced track of the SSP does. 

What’s Next? 

The AAFP continues to review the proposed rule ahead of providing comments to CMS before the Sept. 9 deadline. The final rule will be released around Nov. 1, and will take effect on Jan. 1, 2025, except where specified otherwise in the final rule. 

Latest Payment Advocacy 

The Academy is encouraging members to join a Speak Out campaign calling on Congress to pass the Strengthening Medicare for Patients and Providers Act. The legislation would ensure annual inflationary updates to Medicare payment based on the Medicare Economic Index, as the AAFP has long advocated, alongside a plurality of medical and specialty organizations.