MGMA concerned by 2025 Medicare Physician Fee Schedule
In a recent 28-page letter to the Centers for Medicare and Medicaid Services (CMS), the Medical Group Management Association (MGMA) expressed concerns regarding the proposed 2025 Medicare Physician Fee Schedule (PFS). With the anticipated changes poised to impact Medicare reimbursements, telehealth flexibilities and administrative requirements, MGMA warns that the proposed adjustments could create financial pressures on medical group practices and potentially affect patient care.
"It's very impactful, with CMS proposing a 2.8% cut to the Medicare conversion factor. There's also some key issues with telemedicine reimbursements expiring at the end of 2024. So those two issues especially have been the focus of our comments. But again, as you said, Dave, it's a 28 page letter, so we do get into a degree of commenting on loss of specific proposals as well," explained Anders Gilberg, MGMA's senior vice president of government affairs, in an interview with HealthExec.
One of MGMA's primary concerns is the proposed 2.8% reduction to the Medicare conversion factor for 2025. Gilberg highlighted how conversion factor cuts in recent years have compounded financial strain for medical groups, with inflationary pressures worsening the situation. MGMA is calling for collaboration with Congress to implement a positive update to the conversion factor that reflects the inflationary environment, noting that ongoing reductions threaten the quality and accessibility of care for Medicare beneficiaries.
Telehealth flexibilities in jeopardy
The expiration of COVID-era telehealth flexibilities at the end of 2024 is another pressing issue. CMS implemented telehealth expansion provisions during the pandemic, allowing Medicare patients to access care remotely, including audio-only options. MGMA has urged CMS to extend these provisions and has called for permanent telehealth coverage where appropriate.
“Without action from CMS and Congress, essential telehealth services may no longer be available, disrupting access to care for many patients,” Gilberg emphasized.
Burden of MIPS and the value-based care transition
MGMA also commented on the challenges medical practices face under the Merit-based Incentive Payment System (MIPS). While MIPS was designed to move physicians toward value-based care, MGMA argues that the program’s current structure creates excessive administrative burden. MGMA urges CMS to work with Congress to refine MIPS and make it more clinically relevant. The organization is also asking that MIPS Value Pathways (MVPs) remain voluntary until alternative care models are sufficiently developed.
Advanced payment model incentives
In its letter, MGMA called on CMS to work with Congress to reinstate the Advanced Payment Model (APM) incentive payment at 5% and to maintain current APM qualifying thresholds. The association cautions that without this incentive, practices may lack motivation to engage in value-based care models, undermining CMS’s goal of transitioning to these models by 2030.
"The shift towards value-based care needs a realistic pathway that avoids penalizing those who attempt it," Gilberg said.
MGMA’s commitment to Medicare payment reform
As MGMA awaits CMS’s final 2025 fee schedule, Gilberg emphasized that reform is essential, given the combined impact of conversion factor cuts, telehealth uncertainties, and the MIPS administrative load. With MGMA’s recommendations, the organization hopes to see a sustainable Medicare payment system that supports high-quality, accessible care while reducing financial and administrative pressures on healthcare providers.
The final rule on the Medicare 2025 Physician Fee Schedule is expected in November, at which point MGMA will assess how CMS has addressed these critical concerns and determine next steps in their advocacy efforts.