LUGPA Policy Update - Comprehensive Comments on CY 2025 Medicare Physician Fee Schedule Proposed Rule

Sept. 2024 

In early September, LUGPA submitted detailed new feedback on the Calendar Year (CY) 2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule, addressing significant challenges facing independent urology practices.

Despite the end of the COVID-19 Public Health Emergency, healthcare providers are navigating a complex landscape of rising costs, staffing shortages, supply chain disruptions, and soaring medical malpractice claims. These pressures disrupt physicians' ability to provide high-quality patient care and contribute to widespread burnout and early retirement across the healthcare workforce.

The most pressing concern is the proposed 2.8% payment cut for 2025, which exacerbates the financial strain on independent practices already burdened by inflation and increasing costs in nearly every area of healthcare. LUGPA asserts that while regulatory guidelines may mandate these cuts, CMS is responsible for considering their broader impact and pursuing strategies that promote long-term goals such as patient access, quality improvement, and cost reduction.

In the comment, LUGPA warns that the continued erosion of the MPFS contributes to healthcare consolidation, ultimately driving up costs and diminishing access to care. In response, we made several recommendations to CMS:

Mitigating Payment Reductions

LUGPA urges CMS to adjust the conversion factor calculation to mitigate the effects of the proposed reduction. Given the rising costs faced by all independent practices, this cut would have significant negative consequences for patient care and practice sustainability. LUGPA stresses that CMS should take steps to ensure that payment policies align with the financial realities of modern healthcare delivery.

Enhancing Use of Complexity Add-on Code G2211

LUGPA supports expanding the use of complexity add-on code G2211 by allowing its application alongside modifier -25. This adjustment would provide greater reimbursement flexibility for physicians managing complex cases, thereby promoting high-quality, individualized care for patients with multifaceted health needs.

Reconsidering Cuts to CCM/PCM Codes

LUGPA calls on CMS to reconsider the proposed cuts to Chronic Care Management (CCM) and Principal Care Management (PCM) codes. LUGPA believes that rather than reducing reimbursement for these essential services, CMS should increase the rates to encourage broader adoption of these critical management services, particularly for patients with chronic conditions who require consistent, ongoing care.

Cystoscopy Supply Pack Pricing Update

To prevent sudden and disruptive shifts in the site of service, LUGPA recommends that CMS implement a phased-in approach to the pricing update for the Cystoscopy Supply Pack. A more gradual transition would help practices adjust and avoid potential service interruptions that could negatively impact patient care.

Finalizing the Optimal Care for Patients with Urologic Conditions MVP

LUGPA supports finalizing the new MVP (MIPS Value Pathway) for Optimal Care of Patients with Urologic Conditions, with recommended modifications. Ensuring that specialists have ongoing opportunities to participate in MIPS is essential for advancing quality measures specific to their fields. Additionally, LUGPA provided feedback on proposed changes to the Quality Payment Program (QPP) to further enhance specialty provider involvement.

Telehealth Payment Parity and Flexibilities

LUGPA strongly advocates for CMS to codify payment parity for telehealth services, ensuring that telehealth visits are reimbursed at the same rate as in-person visits. LUGPA also opposes the proposed requirement for a telehealth-specific modifier, arguing that it would unnecessarily increase coding complexity and potentially confuse patients. Additionally, LUGPA supports CMS’s proposal to allow audio-only communication technology to qualify as an "interactive telecommunications system" and to extend the definition of "direct supervision" to include audio-video technology through CY 2025.

Overpayment Timeline and Clinical Labor Adjustment

LUGPA encourages CMS to finalize its proposed overpayment timeline regulations and to pause the timeline for the clinical labor adjustment. These actions would provide much-needed financial stability to independent practices as they navigate the current challenging economic environment.

Transfer of Care Modifiers for Global Packages

LUGPA urges CMS to exercise caution when implementing transfer-of-care modifiers for global packages. To avoid confusion and unintended burdens on community providers, CMS should ensure that any changes are carefully considered and clearly communicated to minimize administrative disruptions.

LUGPA's comments emphasize the importance of preserving independent practices amid rising costs and regulatory challenges. By addressing these issues, CMS can help ensure physicians remain focused on what matters most—delivering high-quality, patient-centered care. LUGPA calls for thoughtful reforms to the MPFS that prioritize patient access, practice sustainability, and healthcare innovation.

The complete comment can be found here.