CMS Releases Calendar Year (CY) 2025 Medicare Physician Fee Schedule Proposed Rule

The Centers for Medicare & Medicaid Services’ (CMS) CY2025 Physician Fee Schedule (PFS) Proposed Rule, released in preview form on July 10, 2024, contains various provisions that will impact federally qualified health centers’ (FQHC) service offering and payment under Medicare. The rule contains provisions that will, if finalized, allow for various service expansions and enhancement in payments for FQHCs in Medicare, as well as building on the trend of greater recognition of technology-based services in Medicare. In particular, the proposals, if finalized, would allow CMS to carry out the following in CY2025:

1.  Broaden the capacity for FQHCs and other providers to use audio-only telehealth, rather than the audio-visual modality, where necessary to support patient care;

2.  Allow FQHCs to furnish and be paid for Medicare advanced primary care management (APCM) services—a more comprehensive approach to primary care targeted to individuals with greater clinical needs—and to receive additional payments for use of the APCM model;

3.  Require, for the first time, that FQHCs and rural health clinics (RHCs) bill Medicare for care management and care coordination using detailed codes; this change will allow FQHCs to be paid more for more resource-intensive care management services, and also to be paid add-on fees for add-on fees if time is spent on care management in a month in excess of the threshold requirement;

4.  Provide, for the first time, for separate initial payment to FQHCs for the administration of Medicare Part B-covered preventive vaccines including hepatitis B, pneumococcal, influenza, and COVID-19 vaccines (with payment for all of the latter three being later reconciled to the FQHCs’ documented costs on its cost report);

5.  Refine the payment methodology for FQHCs for intensive outpatient services (IOP), a behavioral health service added to the Medicare FQHC benefit effective Jan. 1, 2024, so that FQHCs could be paid at a higher rate for days of IOP services where more than four services are provided in a single day;

6.  Rebase the FQHC market basket inflationary index (CMS has done this only one time prior since the inflationary index was first introduced in 2017); and

7.  Postpone further (until Jan. 1, 2026) the implementation of a requirement that patients receiving telecommunications-based mental health visits in an FQHC have had an in-person mental health visit during the six months prior to the initiation of the telecommunications-based care.

Comments are due by Sept. 9. Click here to learn more and access the proposed rule.

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