Medicare Physician Fee Schedule Comments

IPSIS submitted comments 🔒 to the Centers for Medicare and Medicaid Services (CMS) in response to the 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule. Comments focused on four main areas:

• Conversion Factor
  IPSIS strongly recommends that CMS take action to eliminate the conversion factor reduction and advocate for Congress to establish a permanent annual update to Medicare physician payments, linked to the Medicare Economic Index and adjusted for inflation.
  
  
• Merit-based Incentive Payment System (MIPS)
  CMS proposed to maintain the MIPS performance threshold at 75 points. IPSIS urged CMS to implement measures aimed at easing the workload for MIPS-eligible physicians throughout the 2025 performance period and decrease the existing performance threshold of 75 points to prevent unjust penalties.
  
  
• Telehealth Services
  CMS has proposed not to reimburse the 16 newly established audio-visual (AV) and audio-only (AO) telemedicine evaluation and management (E/M) codes developed by the American Medical Association. IPSIS urged CMS to support the utilization of these codes since adoption by other payors is likely. Without CMS support, there is a risk of inconsistent coverage across payors, which could complicate access to telemedicine services.
  
  
• Overpayment Provisions of the Affordable Care Act (ACA)
  CMS has proposed changes to the repayment deadlines for overpayments under Medicare Parts A and B. IPSIS fully supports the modification of the standard 60-day repayment deadline to allow sufficient time for investigating and calculating overpayments and urges CMS to provide clear guidance, ensuring that practices have adequate time to arrange funds and complete payment once the total repayment amount has been determined

Click here 🔒 to read the letter. IPSIS continues to monitor and comment on CMS rule-making activities on behalf of interventional pain physicians and their patients.

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