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CMS Innovation Center Seeks Input on New Proposals in CY 2025 PFS Proposed Rule

The CY 2025 Physician Fee Schedule (PFS) Proposed Rule [ https://www.federalregister.gov/public-inspection/2024-14828/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule ] released today includes requests for information (RFIs) and proposals that would aim to increase accountable care relationships, reduce administrative burden, engage specialty providers in value-based care, and better align payment with quality measures. The PFS Proposed Rule is open for public comment until September 9, 2024.

*RFI on Improving Ambulatory Specialty Care*

The RFI, “Building Upon the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) Framework to Improve Ambulatory Specialty Care,” solicits feedback on the design of a potential model to increase the engagement of specialists in value-based care [ https://www.cms.gov/priorities/innovation/key-concepts/value-based-care ]. Under the potential model, participants would receive a payment adjustment based on their performance compared to other similar specialists on a set of clinically relevant MVP measures. The model would purposely overlap with other CMS accountable care models and programs.

*RFI on Advanced Primary Care Management Services*

CMS is proposing Advanced Primary Care Management payment and coding rules that would bundle elements of existing care management and communication technology-based services into three levels based on certain patient characteristics, such as number of chronic conditions and enrollment as a Qualified Medicare Beneficiary. This proposed coding, intended to reduce administrative burden, incorporates lessons learned from the CMS Innovation Center's testing of a series of advanced primary care models, such as Comprehensive Primary Care Plus [ https://www.cms.gov/priorities/innovation/innovation-models/comprehensive-primary-care-plus ] and Primary Care First [ https://www.cms.gov/priorities/innovation/innovation-models/primary-care-first-model-options ]. The Federal Register also includes an RFI seeking input on how to evolve this code set over time to create a permanent hybrid payment option for primary care and to reach CMS’s goal of having all beneficiaries in an accountable care relationship by 2030.

*New APP Quality Measures*

The Alternative Payment Model (APM) Performance Pathway (APP) rule proposes the APP Plus measure set, offering clinicians who participate in a MIPS APM a more robust opportunity for quality measurement. The measure set would be optional for MIPS eligible clinicians, groups and APM entities that participate in a MIPS APM but required for Shared Savings Program ACOs. For more information, visit the Quality Payment Program Fact sheet [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2876/2025-QPP-Proposed-Rule-Fact-Sheet-and-Policy-Comparison-Table.pdf ].

*New Cardiovascular Risk Assessment and Management Coding and Payment*

CMS seeks comments on proposed coding and payment for risk assessment and management for patients at risk for cardiovascular disease. These interventions were tested in the CMS Innovation Center’s Million Hearts Model [ https://www.cms.gov/priorities/innovation/innovation-models/million-hearts-cvdrrm ], which coupled payments for cardiovascular risk assessment with cardiovascular care management, and was found [ https://www.cms.gov/priorities/innovation/data-and-reports/2023/mhcvdrrm-finalannevalrpt ] to reduce the rate of death by lowering heart attacks and strokes amongst people with Traditional Medicare.

*Updates to the Medicare Diabetes Prevention Program*

CMS also seeks comments on proposed changes to the Medicare Diabetes Prevention Program (MDPP). The CY 2025 PFS proposes changes to align the model with the Centers for Disease Control and Prevention (CDC) 2024 Diabetes Prevention Recognition Program Standards, clarify delivery modes for MDPP make-up sessions, add an option for self-reporting weight for an MDPP distance learning session, add a modifier to help Medicare Administrative Contractors (MACs) to process same day make-up sessions in MDPP, remove the MDPP bridge payment, and align rule language with previous rulemaking.

For more information on the full CY 2025 PFS Proposed Rule, go to the CMS Press Release [ https://www.cms.gov/newsroom/press-releases/hhs-proposes-physician-payment-rule-drive-whole-person-care-and-improve-health-quality-all ] and Fact Sheet [ https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-medicare-physician-fee-schedule-proposed-rule ].

To submit comments, go to the full Notice of Proposed Rulemaking in the Federal Register: https://www.federalregister.gov/public-inspection/2024-14828/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule

Follow us on X (formerly Twitter [ https://twitter.com/CMSinnovates ])  | Visit the CMS Innovation Center website [ https://www.cms.gov/priorities/innovation/overview ]

Centers for Medicare & Medicaid Services (CMS) has sent this update. To contact Centers for Medicare & Medicaid Services (CMS) go to our contact us [ http://www.cms.gov/About-CMS/Agency-Information/ContactCMS/index.html ] page.

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