2025 Medicare Physician Fee Schedule – Updates You Should Know About

• Medicare Payments and Conversion Factor. CMS finalized a 2.83% reduction in the 2025 Medicare PFS conversion factor. This decrease stems from the final year of the 4-year transition of clinical staff wage increases. While the wage increase is appropriate, it disproportionately impacts physician services that utilize high-cost supplies and equipment due to budget neutrality constraints. 
• Telehealth. The rule permanently expands the definition of an “interactive telecommunications system” to include audio-only services, which is important for patients with mobility issues. The rule also extends the suspension of frequency limitations on telehealth services and does not require physicians to report their home address for telehealth through 2025. 
• Merit-Based Incentive Payment System (MIPS) and MIPS Value Pathways (MVPs). While CMS has indicated a potential phaseout of MIPS by 2029 with a mandatory transition to MVPs, no formal proposal has been finalized. CMS proposed maintaining the threshold to avoid a MIPS penalty at 75 points for the CY 2025 performance year/2027 MIPS payment year. AANEM supports simplifying MIPS but raises concerns about MVP applicability for its members due to limited relevant quality measures. The rule finalizes 6 new MVPs, including a consolidated neurology MVP. The rule also removes the requirement for MVP participants to select a population health measure during registration. 
• Subgroup Reporting. The rule maintains that multispecialty groups reporting MVPs must do so at the subgroup level starting in the 2026 performance period. 
• Data Submission. CMS finalized minimum criteria for data submission in MIPS performance categories to prevent penalties for inadvertent submissions with incomplete data. Additionally, the rule finalizes scoring the most recent submission in the Quality and Improvement Activities categories when multiple submissions are received from the same organization. 
• Quality Performance Category. CMS finalized the use of a flat benchmarking methodology for a subset of topped-out measures and lifted the 7-point cap. 
• Cost Performance Category. The rule adds 6 new episode-based cost measures and revises 2 existing ones. 
• Performance Threshold. CMS maintains the performance threshold at 75 points for the 2025 performance period. 
• Evaluation and Management (E/M) Visits. CMS finalized modifications to the G2211 complexity add-on code, removing restrictions on its use with certain preventative services.

For a more detailed summary of the changes to RVUs for codes specific to electrodiagnostic and neuromuscular medicine, members may log in to the Member-Only Coding Resources found on the AANEM website under Practice. If you have questions or concerns about the final rule, you can email the policy department at policy@aanem.org.