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July 19, 2024
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RPA: Proposed Medicare Physician Fee Schedule cut should be mostly neutral for nephrology

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Key takeaways:

  • CMS has proposed reducing its Medicare Physician Fee Schedule conversion factor by 2.8% from $33.29 to $32.36 for 2025.
  • Payment for vascular access procedures would increase by 2.6%.

Proposed changes released earlier this month by CMS to the Medicare Physician Fee Schedule for 2025 should have a minimal impact on payments to nephrologists, according to a summary by the Renal Physicians Association.

The proposed rule calls for a 2.6% increase in payment for vascular access procedures.

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“Positively, the relative value units (RVUs) for most services commonly provided by nephrologists either experienced slight increases or held steady,” Robert Blaser, director of public policy for the RPA, wrote in the association’s weekly newsletter, RPA Weekly eNews. He added, “ ... [W]ith the exception of the expected conversion factor (CF) cut, the news was neutral to positive for nephrology.”

In the proposed rule, CMS would cut the CF, the multiplier which the agency uses to increase or decrease overall reimbursement to Medicare Part B providers, to $32.36, a decrease of 2.8% from the current 2024 CF of $33.29, “due to the legislatively mandated formula,” Blaser wrote, “although as in recent years it is anticipated that Congress will at least partially address this shortfall before year’s end.”

Last year, Congress included language in a bill averting a government shutdown that reduced the impact of a planned 3.37% cut by CMS by 1.68%, leading to the current rate of $33.29.

RVUs

In the summary, Blaser wrote that “there were no major shifts in relative value units (RVUs) on the codes commonly provided by nephrologists. The inpatient and outpatient dialysis code families mostly had incremental upward adjustments. For example, the RVUs for CPT code 90960, (adult monthly outpatient dialysis, four visits), increased from 10.50 to 10.61, and the RVUs for CPT code 90966 (monthly home dialysis care) from 8.72 to 8.81. Refinements of that level or less happened for all of the dialysis codes, both adult and pediatric, inpatient and outpatient [dialysis], home and in-center.”

While the proposed rule did not include major changes for high-volume evaluation and management codes and all of the care management code families, Blaser wrote, CMS is considering coverage of some dental services for patients on dialysis.

“In this year’s rule, CMS proposes that payment can be made for certain dental services associated with dialysis treatments for end-stage renal disease and includes a request for comment about dental services related to diabetes care and covered services for individuals with autoimmune diseases receiving immunosuppressive therapies,” according to a CMS press release.

Two quality measures for nephrologists – both regarding the number of patients placed on the waitlist for a kidney transplant – are being proposed for 2025. “RPA has previously opposed these measures as being outside of the control of the nephrologist,” Blaser wrote.

AMA responds

Bruce A. Scott, MD, president of the AMA, said the proposed cut highlights the need for Medicare payment reform.

“With CMS estimating a fifth consecutive year of Medicare payment reductions ... it’s evident that Congress must solve this problem,” he said in a statement. “In addition to the cut, CMS predicts that the Medicare Economic Index — the measure of practice-cost inflation — will increase by 3.6%. Facing this widening gap between what Medicare pays physicians and the cost of delivering quality care to patients, physicians are urging Congress to pass a reform package that would permanently strengthen Medicare.”

According to the AMA, physician payments have declined 29% from 2001 to 2024, which does not account for the latest proposed reduction.

Comments on the proposed rule are due Sept. 9; the published document can be found at https://www.federalregister.gov/public-inspection/2024-14828/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule.

References:

Congress must act on Medicare payment reform as CMS warns of more cuts. https://www.ama-assn.org/press-center/press-releases/congress-must-act-medicare-payment-reform-cms-warns-more-cuts. Published July 10, 2024. Accessed July 11, 2024.

HHS proposes physician payment rule to drive whole-person care and improve health quality for all individuals with Medicare. https://www.hhs.gov/about/news/2024/07/10/hhs-proposes-physician-payment-rule-drive-whole-person-care-improve-health-quality-all-individuals-medicare.html. Published July 10, 2024. Accessed July 11, 2024.

Implications of 2025 Medicare Fee Schedule: Proposed rule for nephrology. https://cdn.ymaws.com/www.renalmd.org/resource/resmgr/2024/public_policy_updates/2025_MFS_NPRM_Summary-7-2024.pdf. Accessed July 18, 2024.

2025 proposed Medicare Physician Fee Schedule highlights urgent need for Medicare payment reform. https://www.aafp.org/news/media-center/statements/2025-proposed-medicare-physician-fee-schedule.html. Published July 10, 2024. Accessed July 11, 2024.