For the fifth year in a row, the 2025 CMS Medicare Physician Fee Schedule (MPFS) forecasts a reduction in the Medicare conversion factor used to calculate physician payments, which at $32.36 represents a 2.80% payment decrease compared with 2024. In 2024, physicians had a 1.68% pay cut (reduced by Congress from the planned 3.37% pay cut) and they remain the only Medicare providers to not receive an inflationary update.
The Centers for Medicare and Medicaid Services (CMS) proposes to maintain the Merit Based Incentive Payment System (MIPS) performance threshold at 75 points and the 75% data completeness criteria. The penalty for failing to participate in MIPS – if “eligible” (Medicare’s euphemism for “mandatory”) – also remains at 9% of Medicare billing. (Clinicians can determine whether MIPS participation is mandatory for them.)
Other potential MIPS updates include:
- Adding six cost measures
- No changes to the promoting interoperability category; and
- Continued development of MIPS Value Pathways (MVPs) as a voluntary and optional, for now, alternative quality reporting method for specialists.
If the six newly proposed MVPs (ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care) are finalized, CMS estimates that 80% of specialties would have an applicable MVP in 2025. CMS has proposed making participation in an MVP mandatory by 2026.
It is important to note that a cost measure for “non-pressure ulcers” was developed and field tested this year with disappointing results (see links below). Without a medical specialty for wound management, there is no physician organization able to take the lead in the development of an MVP for wound care, and certainly no funding to pay for such an undertaking. However, if participation in an MVP becomes mandatory, physicians who are practicing wound care might instead be required to participate in the MVP associated with their primary specialty (e.g., Family Practice, Emergency Medicine, Internal Medicine, etc.). It is not clear what the payment implications would be to individual wound care practitioners or the field. It is important to note that practitioners who change their specialty designation to Undersea and Hyperbaric Medicine are exempt from having to report a cost measure, and this would seem to represent a way of avoiding potential problems with mandatory MVP participation.
Links for more information on the “Non-pressure ulcer” cost measure under development:
- On Feb 1st, CMS Started Testing the “Non Pressure Ulcers Episode-Based Cost Measure.” What the Heck is That, and Why Should You Care? – Caroline Fife M.D. (carolinefifemd.com)
- Check Out My “Non-Pressure Ulcer” Field Test Report! (and download your own!) – Caroline Fife M.D. (carolinefifemd.com)
- Quick Guide to Reviewing Your Medicare Field Test Report – Caroline Fife M.D. (carolinefifemd.com)
- More Trouble with Field Testing… – Caroline Fife M.D. (carolinefifemd.com)
