2025 MEDICARE PHYSICIAN FEE SCHEDULE (MPFS)
FINAL RULE RELEASED
Includes 2025 Quality Payment Program
Final 2025 Conversion Factor: $32.35
This afternoon, CMS released the CY 2025 MPFS Final Rule, along with a press release, a physician fee schedule fact sheet, and a shared savings program fact sheet.
2025 MPFS Conversion Factor
The final rule announced a CY 2025 MPFS conversion factor of $32.35, a decrease of approximately 2.8% ($0.94) from the CY 2024 MPFS conversion factor of $33.2975. The CY 2025 MPFS conversion factor reflects the following:
- the 0.00% overall update required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA);
- the expiration of the 2.93% increase in payment for CY 2024 mandated by Congress in 2024;
- a 0.02% budget neutrality adjustment.
According to the CMS estimated impact on total allowed charges by specialty (Table 110), ophthalmology will see an overall reduction of -2%. For CY 2025, the final Medicare payment rate for 66984 is $521.75, a 3% decrease from the 2024 Medicare payment of $537.26.
Improving Global Surgery Payment Accuracy
Transfer of Care Modifiers for Global Packages
For CY 2025, CMS is broadening the applicability of the transfer of care modifiers for global packages and will require the use of the -54 modifier in any case when a practitioner furnishes only the surgical procedure portion of the global package (including both formal and other transfers of care).
After reviewing comments, CMS is not finalizing any changes regarding the use of modifier -55 and modifier -56 for CY 2025. Modifiers -55 and -56 will continue to be billed exclusively in cases where there is a documented formal transfer of care. CMS will continue to assess the full range of modifiers for future consideration.
New Add-On Code for Post-operative Care Services; GPOC1
For CY 2025, CMS has finalized a new add-on code, GPOC1, for post-operative care services to more appropriately reflect the time and resources involved in post-operative visits to reimburse for additional resources for those practitioners who were not involved in furnishing the surgical procedure. After reviewing comments, CMS concluded that the “code should not be billed by another practitioner in the same group practice as the practitioner who performed the surgical procedure. In cases where the practitioner furnishing the post-operative care is of the same specialty as the surgeon but not within the same group practice, they would be able to bill for HCPCS code G0559 given the time and resources that could be incurred by a practitioner who is providing post-operative care when they themselves did not perform the actual procedure.”1
“Complexity” Add-on Code
For CY 2025, CMS has finalized their proposal to allow payment of the O/O E/M visit complexity add-on code G2211 when the O/O E/M base code is reported by the same practitioner on the same day as an annual wellness visit (AWV), vaccine administration, or any Medicare Part B preventive service furnished in the office or outpatient setting.
Drugs and Biological Products Paid Under Medicare Part B; Discarded Drug Amounts
Over the last few years, CMS finalized many policies which established a refund for discarded amounts of certain single-dose container or single-use package drugs under Part B.
In this final rule, CMS finalized the provision to clarify several policies implemented in CY 2023 and CY 2024, including: exclusions of drugs for which payment has been made under Part B for fewer than 18 months from the definition of refundable single-dose container or single-use package drug; and identifying single-dose containers.
They have finalized requiring the JW modifier if a billing supplier is not administering a drug, but there are discarded amounts during the preparation process before supplying the drug to the patient.
In addition, CMS has finalized its provision to include injectable drugs with a labeled volume of 2 mL or less, and that lack the package type terms and explicit discard statements in their product labeling, to be single-dose containers in the definition of refundable single-dose container or single-use package drugs.
Medicare Telehealth Services
For CY 2025, CMS has added several services to the Medicare Telehealth Services List.
Interactive Telecommunications System
CMS has finalized that, beginning January 1, 2025, an interactive telecommunications system may include two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system but the patient is not capable of, or does not consent to, the use of video technology.
Distant Site Practitioner
In addition, they have finalized that, through CY 2025, CMS will continue to permit the distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.
Direct Supervision
CMS has also finalized, for a certain subset of services that are required to be furnished under the direct supervision of a physician or other supervising practitioner, to permanently adopt a definition of direct supervision that allows the physician or supervising practitioner to provide such supervision through real-time audio and visual interactive telecommunications. The physician or supervising practitioner may provide such virtual direct supervision for services furnished incident to a physician’s service when they are provided by auxiliary personnel employed by the physician and working under his or her direct supervision and for which the underlying HCPCS code has been assigned a PC/TC indicator of office or other outpatient visit for the evaluation and management of an established patient who may not require the presence of a physician or other qualified healthcare professional.
For all other services furnished under the direct supervision of the supervising physician or other practitioner, they will continue to define “immediate availability” to include real-time audio and visual interactive telecommunications technology only through December 31, 2025.
Teaching Physicians
In addition, the final rule continues the current policy to allow teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in all teaching settings, but only in clinical instances when the service is furnished virtually through December 31, 2025. This virtual presence will continue to meet the requirement that the teaching physician be present for the key portion of the service.
Quality Payment Program Quality Payment Program
MIPS Value Pathways (MVPs)
CMS has finalized 6 new MVPs for 2025, including the Complete Ophthalmologic Care MVP.
Although the finalized ophthalmic MVP is a significant improvement over the draft MVP that CMS released previously and takes into account many of our quality measure suggestions, particularly for cataract surgeons, it is still incomplete. This MVP does not include our suggested measures for refractive or cornea subspecialists. As it is finalized, this MVP does not include any specialty-specific quality measures for refractive or cornea subspecialists. Despite making no changes to the proposed MVP, CMS has stated that they will monitor the MVP in the coming years.
Performance Threshold Proposals
CMS has finalized their proposal to keep the performance threshold at 75 points for the 2025 performance year.
Performance Category Weights
For the 2025 performance year/2027 payment year, the performance category weights are the following:
- 30% for the Quality performance category.
- 30% for the Cost performance category.
- 15% for the Improvement Activities performance category.
- 25% for the Promoting Interoperability performance category.
Quality
CMS will maintain a data completeness threshold of 75% for 2027 and 2028 performance periods.
Cost
Cataract Cost Measure: CMS has finalized the following significant changes to the cataract cost measure in 2025:
- Name change: Cataract Removal with Intraocular Lens (IOL) Implantation [previously Routine Cataract Removal with IOL Implantation]
- Reduced exclusions: The revised measure includes patients with certain previously excluded ocular conditions, such as glaucoma and macular degeneration, in the measure cohort.
- Increased List Included Costs: Added Medicare Part B drugs – Dextenza and IHEEZO and expanded the list of services included in the measure’s cost calculation.
Rheumatoid Arthritis Cost Measure: In a huge win for our advocacy efforts, CMS removed ophthalmic medications from the new Rheumatoid Arthritis episode-based cost measure specifically to ensure that “MIPS eligible clinicians prescribing ophthalmic medications for other purposes, but who are not providing broader treatment and management for rheumatoid arthritis” are not attributed this measure.
Cost Measure Scoring: In another win, CMS has finalized a change to the way in which they score cost measures beginning with the 2024 performance period. Rather than creating scoring deciles based on percentiles, CMS will now use standard deviations. This would likely decrease the likelihood of inappropriately low scores for measures that have little variation in total costs (such as the cataract measure).
Improvement Activities
CMS has finalized the removal of the most popular improvement activity among ophthalmologists beginning in 2025: IA_EPA_1 (24/7 Patient Access). CMS delayed the removal of another popular improvement activity, IA_CC_1 (Close Referral Loop), to performance year 2026.
CMS has also finalized significant changes to how the category is reported by removing activity weights (medium vs high) and, instead, requiring the following:
- Those in MVPs, and clinicians, groups, and virtual groups with the small practice, rural, non-patient facing, or health professional shortage area special status, must attest to 1 activity.
- All other clinicians, groups, and virtual groups must attest to 2 activities.
A fact sheet is available on the CY 2025 Quality Payment Program finalized changes.
Additional Details to Come
ASCRS is reviewing the 3,088-page final rule, and additional information will be detailed in upcoming editions of Washington Watch Weekly.
[1] Page 739 of the Final Rule