On July 10, CMS released the calendar year (CY) 2025 Medicare Physician Fee Schedule (MPFS) proposed rule. CMS proposes a CY 2025 conversion factor of $32.3562, down approximately 2.8% from the CY 2024 conversion factor of $33.2875. This is due to the expiration of the 2024 2.93% bump provided by Congress, plus a positive budget neutrality adjustment of 0.05% triggered by CY 2025 policies. As part of the proposals, CMS is addressing its global surgical payment policy by emphasizing the use of transfer of care modifiers and requiring modifiers for follow-up care provided by a practitioner other than the operating surgeon. Overall, CMS estimates that the policy recommendations in the proposed rule will not have a significant financial impact on the specialty of neurosurgery.
For additional details, see:
- CY 2025 MPFS Proposed Rule
- CMS Press Release
- CMS CY 2025 MPFS Fact Sheet
- CMS Rx Drug Inflation Rebate Program Fact Sheet
Comments are due on Sept. 9. Washington Office staff will prepare a summary of the proposal to distribute to our members and will draft a response letter.
A few initial highlights of payment issues of interest to neurosurgeons are below:
- Global Surgical Modifiers. CMS is proposing to broaden the use of the transfer of care modifiers for global packages and require the use of the existing modifiers (-54, -55 and -56) for all 90-day global surgical packages in any case when a practitioner (or another practitioner from the same group practice) expects to furnish only a portion of a global package (including but not limited to when there is a formal, documented transfer of care as under current policy or an informal, non-documented but expected, transfer of care.) CMS also proposes a new E/M add-on code for use by practitioners who did not perform the procedure (i.e., did not bill the global code) but did provide post-procedure care.
- Updated Code Values for New/Revised Services. CMS did not accept the RUC-passed work relative value (RVW) of 18.95 for the new Cat. I code for MRI-guided focused ultrasound (MRgFUS) and have proposed a lower RVW of 16.60. The AANS and the CNS will object to this reduction in our comments, in comments from the RUC and other partners and a meeting with CMS.
- Practice Expense (PE). CMS acknowledges the ongoing American Medical Association Physician Practice Information Survey and has contracted with the RAND Corporation to develop other methods for measuring and updating PE.
- Quality Payment Program (QPP)
- CMS continues to expand upon the Merit-Based Incentive Payment System (MIPS) Value Pathway (MVP) framework by proposing new MVPs —including a problematic Surgical Care MVP that combines measures related to spine surgery, thoracic surgery and general surgery —and seeks feedback on potentially sunsetting traditional MIPS and fully transitioning to MVPs in 2029.
- CMS proposes to revise MIPS scoring methodologies to allow for more successful participation among clinicians reporting specific high-performing quality measures subject to a scoring cap and to enhance cost measure scores, which have traditionally been lower than quality measures scores.
- CMS proposes to maintain the 75-point MIPS performance threshold, which is the minimum number of points needed to avoid a penalty, recognizing the need for consistency and additional time for more recent data not impacted by the COVID-19 pandemic to become available.
- Qualifying Participants (QPs) in Advanced Alternative Payment Models (APMs) will continue to be exempt from MIPS. While QPs will receive a 1.88% APM incentive payment in 2026 (based on eligibility in 2024), QPs will no longer be eligible for an APM incentive payment starting next year. Per statute, starting in 2026, CMS will apply two separate PFS conversion factor updates — one for QPs (0.75%) and one for all non-QP eligible clinicians, including MIPS participants (0.25%). Also, beginning next year, the Medicare payment and patient count thresholds to qualify as a QP will increase under statute, making it more challenging for clinicians to qualify for this track of the QPP. The AANS and CNS are working with Congress to extend the APM incentive and freeze eligibility thresholds at their current level.
