LUGPA Submits Comprehensive Feedback on CY 2025 MPFS and OPPS Proposed Rules, Advocating for Independent Urology Practices

September 2024 

In response to the recent proposals by the Centers for Medicare & Medicaid Services (CMS), LUGPA has taken significant steps to advocate for independent urology practices by submitting detailed comments on the CY 2025 Medicare Physician Fee Schedule (MPFS), the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule.

In the MPFS submission, LUGPA raised critical concerns about the proposed 2.8% payment cut for 2025, stressing its detrimental impact on independent practices already grappling with rising costs, workforce shortages, and inflationary pressures. LUGPA's recommendations urge CMS to adjust payment policies to safeguard patient care and practice sustainability, with specific proposals such as mitigating the payment reduction, enhancing the complexity add-on code G2211, and reconsidering cuts to chronic care management services.

The OPPS comment similarly focuses on protecting the financial viability of independent practices and ensuring equitable access to care. LUGPA supports CMS's efforts to promote site neutrality and reduce administrative burdens on ASCs while advocating for policies that facilitate access to cutting-edge urological technologies. Notably, LUGPA supports the reassignment of key urological codes, the continuation of PFS-equivalent rates for outpatient visits, and the adoption of invoice pricing for OPPS-payable drugs without pricing information.

Both submissions reflect LUGPA’s commitment to advocating for fair and sustainable payment structures that enable independent urology practices to thrive while ensuring patients continue to receive high-quality, accessible care. The full MPFS comment can be accessed here, and the OPPS comment is available here.