The Centers for Medicare & Medicaid Services (CMS) recently finalized changes to the 2025 Medicare physician fee schedule (MPFS), including a 2.83%-reduction in Medicare physician payments set to take effect on January 1, 2025.
Understandably, this move has raised concerns among trade groups and caught the attention of Congress. The American Medical Association (AMA) warns that these payment cuts are unsustainable as practice costs continue to rise. The American Medical Group Association (AMGA) notes that nearly half of its members might need to furlough non-clinical staff, with many also considering reducing their clinical staff or limiting the number of Medicare patients they accept.
To address these challenges, a bipartisan group of House members introduced the Medicare Patient Access and Practice Stabilization Act of 2024 (HR 10073). The bill aims to reform the Medicare physician payment system, which has long been stuck in a cycle of impending cuts and short-term Congressional fixes. The bill proposes linking payments to the Medicare Economic Index (MEI), a measure of practice cost inflation. But with Congress in a lame-duck session, the bill’s progress has since stalled.
It’s unlikely the bill will be voted on before the new Congress is sworn in. However, it’s promising to see Congress taking an interest in Medicare payment reform.
“Right now, advocacy is the top priority,” says Andrea Brault, MD, president and CEO of revenue cycle & practice management firm Brault. "Physicians have a powerful voice in advocating for change. They should be engaging with their Representatives and asking for an end-of-year resolution.”
Providers can use tools like the Physicians Grassroots Network to share their story or email their Representatives in Congress to help make their voices heard.
Maximizing Medicare payments for EM physicians
“These payment cuts hit emergency medicine groups especially hard, particularly those in small or rural practices,” explains Dr. Brault. “That’s why the CMS Quality Payment Program (QPP) is more important than ever for these groups — it can either help offset some of those Medicare losses or make the situation significantly worse.”
QPP, which includes MIPS and APMs, is central to Medicare’s strategy for controlling costs and promoting quality care. As part of the 2025 MPFS, CMS has finalized a number of updates that could have a big impact on emergency medicine, including changes to certain MIPS scoring categories and revisions to the performance threshold for those participating in the APM track.
2025 MIPS updates for emergency medicine
- Quality Measure Changes: In the Emergency Medicine (EM) Specialty Set, CMS removed Quality Measure 254 (Pregnancy ultrasound for a patient with abdominal pain) after determining that it was topped out. Quality Measure 130 (Documentation of current medications) has also been revised to eliminate the age requirement. As a result, EM physicians will now need to track a greater number of encounters for this measure, as it will apply to all patients rather than being age-specific.
- Cost Category Scoring: CMS will also revise the scoring methodology in the Cost category to align more closely with national averages. This change should raise scores for most EM physicians or at least have no negative impact on those with scores near the national median.
- Improvement Activities: In 2025, CMS will simplify the scoring criteria for Improvement Activities. In the past, participants had to choose from a variety of weighted activities. Starting in 2025, only 1-2 activities will be required depending on the practice’s designation. Small and rural practices will need to report on one activity, while other practices report on two.
Emergency medicine MVP update
- CMS reiterated its intention to phase out the current MIPS program in favor of MIPS Value Pathways (MVP), although no specific timeline has been set.
- In 2025, MVP participants will also benefit from changes to the Improvement Activities (IA) category, where they’ll need to submit data for only one activity, compared to two under Traditional MIPS.
Dr. Brault advises EM physicians to take a strategic approach when selecting Improvement Activities and quality measures. Opting for measures that apply to both Traditional MIPS and the MVP track gives you the flexibility to choose the pathway with the higher score at year-end. For instance, in the Improvement Activities category, she recommends targeting “Promoting clinician well-being,” a meaningful option that works across both tracks.
2025 updates for advanced APMs
- Beginning in 2025, the thresholds to achieve Qualified Provider (QP) status will increase to 75% of Medicare Part B payments (up from 50%) or at least 50% of Medicare patients (up from 35%).
- The statutory updates for the APM track have also expired, meaning future bonuses will require Congressional approval, and financial incentives for QPs are no longer guaranteed.
- EM physicians should check their QP status on the CMS website using the QPP Participation Status Tool and entering their 10-digit NPI number. Link Here.
Dr. Brault emphasizes that understanding your QP status is crucial. As thresholds tighten and incentive payments diminish, physicians may need to explore alternative strategies for participating in the QPP.
Looking ahead
The 2025 MPFS presents both challenges and opportunities, and EM physicians must adopt a strategic approach to the Quality Payment Program – focusing on careful planning and active management throughout the year. Dr. Brault also stresses the importance of looking beyond Medicare to understand payment trends across all payers. She explains that effectively managing payment denials and optimizing revenue cycle processes will be key to navigating the changing reimbursement landscape in 2025.
