2025 Medicare Physician Fee Schedule is Out (and CMS Did Not “Package Price” Cellular Tissue Products / Skin Substitutes in the Doctor’s Office)

Medicare Advantage Plans

The Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the 2025 Medicare physician fee schedule (PFS).

The big question in our field was whether CMS would start “package pricing” CTPs/skin subs in the physician office. They didn’t – which surprises me – but at least in 2025, the billing of CTPs in the doctor’s office is unchanged. The 2025 Medicare conversion factor is set to decrease for the fifth straight year. Because of factors specified in law, average payment rates under the PFS are proposed to be reduced by 2.93% in CY 2025 compared to the average amount these services will be paid for most of CY 2024. This amounts to a proposed estimated CY 2025 PFS conversion factor of $32.36, a decrease of $0.93 (or 2.80%) from the current CY 2024 conversion factor of $33.29.

Naturally, everyone is still digesting and analyzing this very big proposed rule, so there is more to come. Click here for a fact sheet on the CY 2025 Physician Fee Schedule proposed rule.

As an aside, I thought the section on “Caregiver Training Services” in techniques to perform dressing changes and prevent “decubitus ulcer” formation was interesting.

Caregiver Training Services (CTS)

For CY 2025, we are proposing to establish new coding and payment for caregiver training for direct care services and supports. The topics of trainings could include, but would not be limited to, techniques to prevent decubitus ulcer formation, wound dressing changes, infection control, special diet preparation, and medication administration. We are also proposing to establish new coding and payment for caregiver behavior management and modification training that could be furnished to the caregiver(s) of an individual patient. We are also proposing to allow the proposed CTS to be furnished via telehealth.

–Caroline

Caroline Fife, MD

Dr. Fife is Co-Founder and Chief Medical Officer of Intellicure, Executive Director of the US Wound Registry, and Editor of Today’s Wound Clinic.

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