2025 Medicare Physician Fee Schedule expands access to social care
In November, the Centers for Medicare & Medicaid Services (CMS) released the final rule for Medicare Part B policy, under the Physician Fee Schedule (PFS) which will go into effect on January 1, 2025.
The final rule furthers the Biden Administration’s commitment to expanding access to behavioral health services, care coordination, and wrap-around supports for Medicare beneficiaries and those involved in their care, and reflects CMS’s overall dedication to gathering information on and testing new methods to address social determinants of health (SDoH):
“We are interested in better addressing the social needs of beneficiaries and requesting information on the codes we created and finalized beginning in CY 2024 to fully encompass what interested parties and commenters believe should be included in the coding and payment we recently established.”
- 2025 Physician Fee Schedule, p. 338
Many of the changes listed in the 2025 Physician Fee Schedule make progress toward CHaSCI’S mission of expanding access to high-quality social care.
Some additional changes made by CMS include:
“We believe that proposing payment for these interprofessional consultations performed via communications technology… is consistent with our ongoing efforts to appropriately recognize and reflect behavioral health care within the PFS.”
- 2025 Physician Fee Schedule, p. 603
Establish new payment for interprofessional consultation services provided by and received by behavioral health professionals including clinical social workers. This is noteworthy because medical providers have been able to receive Medicare reimbursement for their time spent consulting with other medical providers since 2019, so this expansion helps move Medicare toward parity. You can read more here.
Establish new payment mechanisms for safety planning interventions (SPI) when people at risk of a suicidal or substance use-related crisis, and for a specific bundle of post-discharge follow-up contact interventions (FCI) after a crisis-related ED visit or inpatient stay. You can read more here.
Build on the 2024 recognition of select Caregiver Training Services (CTS) with an additional code recognizing individual behavior management and modification training, as well as new coding and payment for caregiver training for direct care services and supports – such as training the caregiver on techniques to prevent decubitus ulcer formation, wound care, and infection control.
“We believe that CTS may be reasonable and necessary when they are integral to a patient's overall treatment and furnished after the treatment plan is established.”
- 2025 Physician Fee Schedule, p. 324
Add services to the Medicare Telehealth Services List, including caregiver training services on a provisional basis.
Expand the list of clinical scenarios under which Fee-for-Service Medicare payment may be made for dental services associated with dialysis services for the treatment of end-stage renal disease.
Create a new preventative care program, Advanced Primary Care Management (APCM), incorporating care management and telehealth services for ongoing primary care services. The APCM billing codes are based on patient characteristics and resource intensity and are divided into three levels: Level 1 for Medicare patients with one or fewer chronic conditions; Level 2 for patients with two or more chronic conditions; and Level 3 for patients with two or more chronic conditions who have QMB or Qualified Medicare Beneficiary Medicare Savings Program. Learn more about APCM here.
To maintain overall budget neutrality, the agency finalized a 2.83 percent reduction in general PFS payment rates for 2025.
The Medicare Physician Fee Schedule final rule was published on December 9, 2024.
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