Well the Final Rule for the 2025 Medicare Physician Fee Schedule (MPFS) dropped into my email Friday about 4:40 pm. Of course they announce this on a Friday evening.
The headline – which should be no surprise – is that the Conversion Factor (CF) will be decreasing by 2.83% from its 2024 value, to $32.35. That will affect all Medicare Part B services.
Here’s what’s happened to the CF since it was first used in 1992.
The CF has lost 10.3% of its value since 2020, in a first-ever 5 straight years of reductions.
Get the idea why health care professionals who must or want to continue taking care of Medicare patients, are pissed? Or, really any insurance that models its reimbursement based on Medicare’s example? (Which is a lot of them). The AMA quickly blasted the Final Rule. And reminded anyone who cares about access to care for Medicare beneficiaries of a legislative fix that has been introduced in Congress. Once again, health care professionals will be holding our breath and lobbying out loud at the same time, to see what Congress will do with an end-of-the-year-or-into-next-year legislative fix. This is no way to run a system that takes care of 65 million people.
There are some nuggets for behavioral health in the 3088 page rule (no, I haven’t read it all. Yet). First, the estimate is that psychologists and social workers could see a combined impact of 3% and 4%, respectively, in estimated allowed charges (psychiatry an estimated 1%).
These specialties are 3 of only 8 specialties which are estimated to show increases in projected allowed charges in 2025. Marriage and Family Therapists and Mental Health Counselors can’t be estimated yet, as 2025 will be their first year in Medicare.
Prediction: The projected increases likely are due to increases in the WORK component of the most common services psychologists and social workers provide: 60 minute therapy sessions (HCPCS 90837), as well as therapy sessions in 30 minute (HCPCS 90832) and 45 minute (HCPCS 90834) increments. They’re not likely due to projected increased productivity. We’ll know more when we see the 2025 RVUs.
Second, telehealth.
(1) The policy allowing “distant site practitioners” to use their currently enrolled practice locations instead of their home address when providing telehealth services from their home is being extended through 2025. This will be welcome news for those who have maintained a shift to all or partial home-based teleahealth practice and are concerned about their own privacy and security, concerns which CMS acknowledges in the Final Rule.
(2) Claims for telehealth services billed with Place of Service 10 (telehealth provided in patient’s home) will be paid at the non-facility PFS rate. The final rule notes “This policy, as finalized, was not limited to CY 2024. Claims for telehealth services billed with POS 10 (telehealth provided in patient’s home) will continue to be paid at the non-facility PFS rate for CY 2025 and beyond.”
Adoption of those policies can be attributed to effective advocacy on behalf of behavioral health practice and the Medicare beneficiaries who need the services.
Maybe Medicare’s lead on the telehealth policies will influence commercial third party payers, but I’d need very good odds to take that bet.
It looks like the Trump administration provided much better rates. Something to keep in mind when voting as leadership makes a difference.
Secondly, how do we opt out of Medicare, just in case?
Has the American Psychological Association weighed in at all on our behalf?
Thank you for your comments Dr. Begali.
In my view, the problems with Medicare financing are structural, have been longstanding, and are well beyond the scope of any particular executive, or administration.
Specific coverage policies may be more amenable to being shaped by an administration’s approach to healthcare. Review of improvements during the Biden-Harris years can be readily compared to other administration periods, and are likely to be favorable when compared to 2017-2020, depending of course on one’s perspective on health care policy, not to mention federal budgeting.
Yes, APA is quite active in pursuing policy for psychologists and the people we take care both in and out of Medicare. In my view the bulk of advocacy though is accomplished by APA Services, Inc. (APASI) APA’s companion c6 organization. APASI can more directly advocate for psychologists, including reimbursement, beyond APA’s more generic mission. And APASI has had notched a number of successes.
Information on opting out can be found here: https://www.cms.gov/medicare/enrollment-renewal/providers-suppliers/chain-ownership-system-pecos/manage-your-enrollment and on the website of your MAC. FWIW, every psychologist’s participation in Medicare matters, though it’s an understandable individual practice sustainability, focus and values issue.
GH