Along with the 2,248-page proposed rule, CMS also published the associated fact sheet that acts to summarize the main provisions of the PR. Based on those documents, we offer the following synopsis of Medicare’s proposals for 2025—especially as they directly or potentially impact the anesthesia community.
Conversion Factors
According to the CMS fact sheet summarizing the proposed fee schedule for 2025, “average payment rates” would be reduced by 2.93 percent in comparison to the average amount these services are being paid this year. The change to the PFS conversion factor incorporates the following:
- 00 percent overall update required by statute
- The expiration of the 2.93 percent increase in payment for 2024 required by statute
- Estimated 0.05 percent adjustment necessary to account for changes in work relative value units (RVUs) for some services
This amounts to a proposed estimated 2025 PFS conversion factor of $32.36, reflecting a decrease of $0.93 (or 2.8 percent) from the current 2024 conversion factor of $33.29.
As to the anesthesia conversion factor that CMS proposes for 2025, it has been tentatively set at $20.3340. This represents a decrease of 2.1 percent from the 2024 anesthesia conversion factor of $20.7739.
The American Society of Anesthesiologists (ASA) lost no time in expressing their dissatisfaction with the proposed conversion factors for 2025. The organization published the following language:
ASA opposes these additional Medicare payment cuts included in the CY 2025 PFS proposed rule. The proposed rule underscores how the Medicare payment system is broken, especially during a time when anesthesia groups are faced with continued inflation pressures. ASA has already launched an initiative to engage legislative stakeholders and regulatory agencies to minimize and reverse these cuts that negatively impact anesthesiologists.
Acute Pain Blocks
On a more positive note, the proposed rule also addressed certain pain procedures that had previously lacked a CPT code and thus had to be submitted with CPT 64999 (Unlisted procedure, nervous system), which did not always guarantee reimbursement. With the urging and agency of the ASA, CMS now recognizes several new block procedure codes, indicating eligibility for payment beginning in 2025. They are as follows: (a) Thoracic fascial plain blocks (6XX07-6XX10), and (b) lower extremity fascial plane blocks (6XX11-6XX12). The American Medical Association (AMA), which publishes the CPT coding manual, has yet to assign the final coding designation for these procedures, but these will be published at the end of this year and will be utilized starting January 1, 2025.
Some of the most common thoracic fascial plane blocks that would be reflected in the new code set are as follows:
- Pectoral I and Pectoral II (PECs I & II)
- Serratus anterior plane
- Erector Spinae plane
- Quadratus lumborum
- Transversus abdominis plane
Lower extremity fascial plane blocks include the following:
- Facia iliaca plane
- PENG
- IPack
All the above procedures are slated to have a recognized coding designation in the new year. However, providers should note that these new codes will bundle imaging guidance. This means you will not be able to separately bill for ultrasound guidance.
The ASA had this to say about the new block codes:
We are happy that CMS accepted the RUC recommendation for the newly created Fascial Plane Block codes. ASA requested new CPT codes in September 2023. ASA surveyed its members in the fall 2023 to develop value recommendations to these codes. The recommendations were presented at the January RUC meeting.
To sum up, while there are new options for a certain category of pain blocks, the overall takeaway is that anesthesia providers continue to be faced with pay cuts from a Medicare conversion factor perspective. Of course, we must wait to see if these proposed cuts will be included in the final rule, which is due out this November. Until then, our readers are encouraged to make their voices heard by sending their comments to CMS. Comments can be sent electronically to https://www.regulations.gov. Follow the “Submit a comment” instructions. Your comments must be received no later than 5 p.m. on September 9, 2024. In commenting, please refer to file code CMS-1807-P.
In the next few weeks, we will provide further highlights from the proposed rule dealing with chronic pain and the quality payment program.