CMS Releases CY 2025 Physican Fee Schedule Final Rule

November 11, 2024-- On November 2, the Centers for Medicare & Medicaid Services (CMS) issued the public inspection version of the Medicare and Medicaid Programs CY 2025 Physician Fee Schedule (PFS) Proposed Rule. The final rule is scheduled to be published in the Federal Register on December 9, 2024. 

‍

There are several components of significant relevance to the delivery of Medicare Part B therapy services. These updates will go into effect on January 1, 2025.

‍

Reimbursement cuts:  As expected, the final rule reflects cuts to payment rates. CMS has finalized the CY2025 conversion factor to be $32.3465, a decrease of $0.94 (or 2.83%) from the current CY 2024 conversion factor of $33.2875. Actual reimbursement reductions will depend on multiple factors, including specialty, codes billed, and geographical area. This cut will be effective January 1, 2025, unless Congress intervenes.

‍

A bipartisan House bill, Medicare Patient Access and Practice Stabilization Act of 2024, was introduced on October 29, 2024, that would increase the conversion factor by 4.73%, essentially preventing the 2.83% cut,and allowing for a 1.9% inflationary payment increase for 2025.

‍

Supervision of PTAs/OTAs in Private/Group Practice: CMS finalized a regulatory change to allow for general supervision of physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) working in private/group practices from direct supervision to general supervision. This aligns with the supervision of PTAs and OTAs who work in institutional settings, such as rehab agencies and skilled nursing facilities, and is an important step in improving access to care.

‍

Certification of Initial Therapy Plans of Care: CMS finalized an exception to the physician/NPP signature requirement on the therapist-established plan of care for initial certification when:

‍

1) there is a signed and dated written order/referral from the patient’s physician/NPP on file specifying the type of therapy (PT, OT, SLP) AND 

2) the therapist has documented evidence that the treatment plan/plan of care was transmitted to the physician/NPP within 30 days of the initial evaluation. 

‍

There is no change to the signature requirement for recertification, and CMS does not plan to propose such changes.

‍

In the proposed rule, CMS solicited comments on time limits for physicians/NPPs to modify the plan of treatment from the date of receipt, AND whether there should be a time limit from when the order is written and when services begin when the order is being used for initial certification. At this time, CMS has not made any changes and will consider the comments for possible future rule-making.

‍

Telehealth Services: As it stands now, the temporary extensions for telehealth are set to expire, by statute, on December 31, 2024. Beginning January 1, 2025, restrictions on telehealth that existed before the COVID-19 Public Health Emergency (PHE) will go back into effect excluding PT, OT and SLPs from providing telehealth. While common therapy codes continue on the provisional Medicare Telehealth List, therapy practitioners are not included on the list of eligible telehealth practitioners. Without Congressional action, PTs, OTs, and SLPs will be excluded from providing telehealth beginning on January 1, 2025.

The Telehealth Modernization Act  (H.R. 7623), would extend pandemic-era telehealth flexibilities in Medicare for another two years, through 12/31/2026. This legislation, introduced in March would include Physical, Occupational, and Speech Therapists as providers of telehealth, expand access to telehealth for Medicare beneficiaries and remove geographic originating site restrictions. The bill could be included in a larger spending package, likely after Congress returns from the election.

Caregiver Training Services: 

• CMS finalized that consent can be provided verbally by the patient or the patient’s representative for Caregiver Training Services (CTS) and documented by the therapist in the patient’s medical record. 
• As noted in the Telehealth section above, CMS added caregiver training codes (CPT Codes 97550 – 97552 and 96202 – 96203) to the Medicare Telehealth Services list for CY 2025 on a provisional basis. 

‍

Powerback Rehabilitation will continue to advocate for a permanent fix to the PFS, legislation that will make permanent current telehealth flexibilities and relief from the proposed PFS cuts.

‍

Additional resources:

• CY 2025 Physician Fee Schedule Proposed Rule
• CY 2025 Physician Fee Schedule proposed rule fact sheet

‍