On November 1, the Centers for Medicare & Medicaid Services (CMS) released the Medicare Physician Fee Schedule (MPFS) final rule for Calendar Year (CY) 2025 (CMS-1807-F). The rule updates payment policies and rates for Part B services furnished under the MPFS, as well as makes changes to the Quality Payment Program (QPP). The rule in its entirety and the addenda, including Addendum B, which lists the proposed RVUs for each CPT^® code can be found here.

CMS finalized several significant policy changes, including creating a new code to address the global surgical package policy, requiring use of a modifier for 90-day global surgeries, redefining telehealth services to include audio-only services, and declining to pay for the new 16 of the 17 telemedicine E/M codes. The following summarizes the major policies of the final rule. Note that the page numbers listed in this document refer to the display copy of the final rule.

• CY 2025 MPFS Impacts on Urology Codes Compared with CY 2024 Rates (Facility and Non-Facility Rates)
• CY 2025 MPFS Impacts on Evaluation & Management Codes Compared with CY 2024 Rates (Facility and Non-Facility Rates)
• The AUA submitted comments on the proposed rule on September 5, 2024

Regulatory Impact Analysis

Highlight: Conversion factor set for a decrease yet again for CY 2025.

Conversion Factor for 2025

The conversion factor for 2025 is set to decrease by approximately 2.83% from $33.2875 to $32.3464. The cut is primarily driven by the expiration of the conversion factor increase that Congress passed in March, coupled with a 0% baseline update.

Changes in Relative Value Unit Specialty Level Impact – p. 2,326

The impact of the final rule’s policies on group practices and individual physicians varies based on practice type, the mix of services provided to patients, and the patient mix. Table 110 of the rule, (Appendix A of this summary) estimates the specialty level impacts of the policies finalized for 2025 and includes impacts of rate-setting changes and changes to RVUs within the budget neutral system. Table 1 below highlights estimated specialty level impacts and includes some of the specialties with the greatest impact, both positive and negative for comparison. Note that the impact table values do not reflect the decrease in the conversion factor for 2025.

Table 1: CY 2025 Estimated Impact Total Allowed Charges by Specialty

Specialty	Medicare Allowed Charges (millions)	Work RVU Impact	PE RVU Impact	MP RVU Impact	Overall Impact
Clinical Social Worker	$894	3%	1%	0%	4%
Endocrinology	$517	0%	0%	0%	1%
Internal Medicine	$9,491	0%	0%	0%	0%
Gastroenterology	$1,453	0%	0%	0%	0%
Urology	$1,617	0%	0%	0%	0%
Obstetrics/Gynecology	$565	0%	0%	0%	-1%
Vascular Surgery	$998	0%	-2%	0%	-2%
Interventional Radiology	$445	0%	-2%	0%	-2%

Determination of Practice Expense RVUs – p. 31

Highlight: No change in the MEI methodology while CMS waits for updated practice expense data from the AMA.

The agency finalized its policy not to adjust RVUs using MEI methodology. The agency reiterated that it would continue to wait for the results of the American Medical Association’s Physician Practice Information Survey before making any significant changes to the data inputs and calculation of the practice expense RVUs.

Supply Pack Pricing Update – p. 49

Highlight: CMS will phase-in, over four years, the revised price for the urology cystoscopy visit pack, and for the supply pack cleaning an endoscope.

The practice expense portion of the MPFS payment formula is comprised of supplies, equipment, and the clinical labor needed to perform each service within MPFS. Recently, the aggregate supplies such as drapes and gowns included in supply packs were updated through the work of the AMA RUC. With the assistance of the AUA, the supply pack for urology cystoscopy services was updated, as was the supply pack for drapes used in cystoscopy. The subsequent revaluation of the urology cystoscopy supply pack resulted in a price decrease from $113.70 to $37.63. Additionally, through this same work with AMA RUC, the price of the supply pack for cleaning and disinfecting an endoscope increased by 61% from $19.43 to $31.29.

The AUA submitted comments recommending that the agency phase-in the revised pricing for the urology cystoscopy supply pack. The urology cystoscopy supply pack is a supply input for 38 codes. Given the large decrease in price, and the impact that this would have on the specialty of urology, CMS agreed with the AUA noting that “the use of a phased-in transition period would be appropriate to allow practitioners to adjust to the updated pricing of these supplies.” Note that CMS also finalized a phased-in approach for the increased price for the supply pack for cleaning and disinfecting an endoscope.

To implement the transition, CMS will phase-in the new prices over four years. Table 2 shows the transition prices from 2025-2028.

Table 2: Supply Pack Price Transition

Supply Pack	2024 Price	Recommended Price	2025 Price	2026 Price	2027 Price	2028 Price
Urology cystoscopy	$113.70	$37.63	$94.68	$75.67	$56.65	$37.63
Drapes, cystoscopy	$19.43	$31.29	$22.40	$25.36	$28.33	$31.29

CY 2025 Clinical Labor Pricing Update – p. 61

Highlight: CMS finalized pricing for clinical labor types.

The agency did not receive new wage data during the comment period or any other information for use in its calculation of clinical labor pricing. Therefore, the data finalized in 2024 will be used for clinical labor pricing again in 2025. Table 8 of the final rule lists the clinical labor types and their price per minute for 2025.

Development of Strategies for Updates to Practice Expense Data Collection and Methodology – p. 71

Highlight: CMS provides no additional information on how it will update practice expense inputs.

The agency said little in the final rule regarding how they intend to update the practice expense portion of the MPFS, and thanked commenters for their input, while noting that CMS will consider comments in future rulemaking. The agency requested information on many topics including alternative data sources to the AMA Physician Practice Information Survey, timing of recurring updates to the practice expense inputs, and the use of four-year phase-in policy when new data is implemented.

Payment for Medicare Telehealth Services under Section 1834(m) of the Act – p. 106

Highlight: CMS adds audio-only communication technology to the definition of a telehealth service. Requests to Add Services to the Medicare Telehealth Services List for CY 2025

CMS plans to complete a comprehensive analysis in future rulemaking of all the services on the Medicare Telehealth Services List provisionally before determining which codes should be made permanent. The process and decision-making parameters that the agency uses to make determinations as to whether a code(s) may be placed on the telehealth service list is found on page 108 of the final rule.

Care Management – p. 122

CMS received a request to permanently add General Behavioral Health Integration (CPT code 99484) and Principal Care Management (CPT codes 99424-99427) to the Medicare Telehealth Services List. The agency does not consider these to be Medicare telehealth services and therefore is not adding these services to the Medicare Telehealth Services List. As noted in the rule the agency states, “We do not consider these services to be Medicare telehealth services because they are not inherently face-to-face services, and the patient need not be present for the services to be furnished in its entirety.”

Posterior Tibial Nerve Stimulation for Voiding Dysfunction – p. 123

The agency received a request to permanently add posterior tibial neurostimulation (CPT code 64566) to the Medicare Telehealth Services list. CPT code 64566 has never been on the telehealth list, nor does the service meet the agency’s criteria for addition to the list. The agency states the services associated with the posterior tibial neurostimulation require an in-person interaction and are not eligible for placement on the telehealth list. However, CMS encouraged stakeholders to continue engagement on this issue, and CMS will continue to evaluate whether posterior tibial neurostimulation for voiding dysfunction services capable of being delivered via an interactive telecommunication system.

Frequency Limitations of Medicare Telehealth Subsequent Care Services in Inpatient and Nursing Facility Settings, and Critical Care Consultations

Prior to the COVID pandemic, there were frequency limitations (i.e., the number of times a provider may bill for a service during a given time frame) for services associated with subsequent inpatient visits (CPT codes 99231, 99232, and 99233), subsequent nursing facility visits (CPT codes 99307, 99308, 99309, and 99310), and critical care consultation services (HCPCS G codes, G0508 and G0509). However, during the pandemic, CMS lifted the frequency restrictions to allow greater access to care.

The agency finalized the proposal to continue suspension of the telehealth frequency limits on subsequent inpatient and nursing facility visits and critical care consultations for CY 2025. This will give the agency to gather an additional year of data to determine how practice patterns are evolving and what changes, if any, should be made to this policy permanently.

Audio-only Communication Technology to Meet the Definition of “Telecommunications Systems”

CMS permanently revised the definition of an interactive telecommunications system to include two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician is technically capable of using an audio/video system, but the patient is not capable of, or does not consent to, the use of video technology. The agency notes that providers should continue to use their clinical judgment to decide if audio-only technology is sufficient to provide a telehealth service.

However, the agency recognizes that lack of access to broadband may make video calls impractical, or that patients may prefer to engage with their provider in their homes using audio-only technology. For claims for audio-only services, providers must use CPT modifier 93 to verify that all conditions have been met. No additional documentation except for the appropriate modifier is needed.

Distant Site Requirements

For CY 2025, CMS finalized the proposal to continue to allow a distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home. The agency will consider proposals to better protect the safety and privacy of providers.

Direct Supervision via Use of Two-way Audio/Video Communications Technology

CMS finalized the proposal to continue to define direct supervision to permit the presence and immediate availability of the supervising practitioner through real-time audio and visual interactive telecommunications systems through December 31, 2025. The agency permanently adopted the definition of direct supervision permitting virtual presence for services that are considered lower risk, such as services that do not ordinarily require the presence of the billing practitioner, do not require as much direction by the billing practitioner as other services, and are not typically performed by the supervising practitioner.

Teaching Physician Billing for Services Involving Residents with Virtual Presence

CMS will continue the current policy, which allows teaching physicians to have a virtual presence when billing for services involving residents in teaching settings only when the service is furnished virtually (i.e., the patient, resident and teaching physician are all in separate locations), through December 31, 2025. The teaching physician’s virtual presence requires real-time observation and excludes audio-only technology.

Telehealth Originating Site Facility Fee Payment Amount Update

For CY 2025, the payment amount for HCPCS code Q3014 (Telehealth originating site facility fee) will be $31.01.

Telehealth Place of Service Code

The agency noted that claims for telehealth services billed with POS 10 (telehealth provided in patient’s home) will continue to be paid at the non-facility PFS rate for CY 2025 and beyond.

Valuation of Specific Codes

Intra-Abdominal Tumor Excision or Destruction (CPT codes 49186, 49187, 49188, 49189, and 49190) – p. 204

The CPT Editorial Panel created five new codes to describe the removal of intra-abdominal tumors based on the sum of the maximum length of the tumor(s). The AUA participated in the RUC survey valuation process.

CMS finalized the RUC recommended work values for 49186, 49187, and 49188. However, for codes 49189 and 49190, CMS finalized lower work values than those recommended by the RUC. The AUA, along with other specialty societies submitted comments supporting the RUC recommended values, but the agency rejected these comments. Therefore, the following CMS-developed values have been finalized; work RVUs of 40.00 and 50.00 for CPT codes 49189 and 49190, respectively.

Bladder Neck and Prostate Procedures (CPT codes 53865 and 53866) – p. 209

CMS accepted the AMA RUC recommended values for new CPT codes that describe services associated with the use of a temporary device that remodels the bladder neck and prostate to alleviate symptoms of the lower urinary tract secondary to benign prostate hyperplasia. The final work RVU of 3.10 was approved for CPT code 53865, while a work RVU of 1.48 was assigned to CPT code 53866.

Additionally, for services associated with CPT codes 53865 and 53866, CMS increased the supply price input for the iTind device used in these procedures. During the comment period, the agency received additional invoices for the device and used submitted invoices to create an average price based all the invoices received during the rate setting process. Therefore, the new supply price for iTind is $2,972.50, a $277.50 increase from the proposed price of $2,695.00.

MRI-Monitored Transurethral Ultrasound Ablation of Prostate (CPT codes 51721, 55881, and 55882) – p. 211

At the April 2023 CPT Editorial Panel meeting, the CPT Panel approved three new codes to describe services associated with MRI-monitored transurethral ultrasound ablation of the prostate. CMS finalized the RUC recommended values for all three services, noted as follows: CPT code 51721 work RVU of 4.05, CPT code 55881 work RVU of 9.80, and CPT code 55882 work RVU of 11.50. The PE inputs have been accepted by CMS, without refinement.

Table 3: RUC Recommended vs. CMS Final Work RVUs for Services of Interest to AUA Members

CPT Code	Descriptor	RUC Recommended Work RVU	CMS Final Work RVU
49186	Excision or destruction, open, intra-abdominal (ie, peritoneal, mesenteric, retroperitoneal), primary or secondary tumor(s) or cyst(s), sum of the maximum length of tumor(s) or cyst(s); 5 cm or less	22.00	22.00
49187	Excision or destruction, open, intra-abdominal (ie, peritoneal, mesenteric, retroperitoneal), primary or secondary tumor(s) or cyst(s), sum of the maximum length of tumor(s) or cyst(s); 5.1 to 10 cm	28.65	28.65
49188	Excision or destruction, open, intra-abdominal (ie, peritoneal, mesenteric, retroperitoneal), primary or secondary tumor(s) or cyst(s), sum of the maximum length of tumor(s) or cyst(s); 10.1 to 20 cm	34.00	34.00
49189	Excision or destruction, open, intra-abdominal (ie, peritoneal, mesenteric, retroperitoneal), primary or secondary tumor(s) or cyst(s), sum of the maximum length of tumor(s) or cyst(s); 20.1 to 30 cm	45.00	40.00
49190	Excision or destruction, open, intra-abdominal (ie, peritoneal, mesenteric, retroperitoneal), primary or secondary tumor(s) or cyst(s), sum of the maximum length of tumor(s) or cyst(s); greater than 30 cm	55.00	50.00
51721	Insertion of transurethral ablation transducers for delivery of thermal ultrasound for prostate tissue ablation, including suprapubic tube placement during the same session and placement of an endorectal cooling device, when performed	4.05	4.05
55881	Ablation of prostate tissue, transurethral, using thermal ultrasound, including magnetic resonance imaging guidance for, and monitoring of, tissue ablation	9.80	9.80
55882	Ablation of prostate tissue, transurethral, using thermal ultrasound, including magnetic resonance imaging guidance for, and monitoring of, tissue ablation; with insertion of transurethral ultrasound transducers for delivery of the thermal ultrasound, including suprapubic tube placement and placement of an endorectal cooling device, when performed	11.50	11.50
53865	Cystourethroscopy with insertion of temporary device for ischemic remodeling (ie, pressure necrosis) of bladder neck and prostate	3.10	3.10
53866	Catheterization with removal of temporary device for ischemic remodeling (ie, pressure necrosis) of bladder neck and prostate	1.48	1.48

Telemedicine Evaluation and Management (E/M) Services (CPT codes 98000, 98001, 98002, 98003, 98004, 98005, 98006, 98007, 98008, 98009, 98010, 98011, 98012, 98013, 98014, 98015, and 98016) – p. 234

As a part of its work in a complete overhaul of the E/M section of the CPT code book, the CPT Editorial Panel created, and the RUC subsequently valued 17 new codes to describe services for the provision of telemedicine E/M services. CMS finalized policy stating that there is no programmatic need to recognize and provide payment for 16 of the 17 newly established telemedicine E/M codes, and therefore assigned 16 of the codes a status indicator of “I” which indicates there is a more specific code that should be used in the Medicare program, in this instance the existing office E/M codes. Instead, the agency states that providers should continue to use the existing office/outpatient E/M CPT codes, which are on the telehealth services list. Providers should use appropriate place of service codes to identify the location of the Medicare beneficiary, and use appropriate modifiers as required.

However, CMS finalized payment for CPT code 98016 (Brief communication technology-based service (eg, virtual check-in) by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment, 5-10 minutes of medical discussion). CMS will delete HCPCS code G2012, used to report similar services, and instead beginning January 1, 2025, providers should use the new CPT code to report a virtual check-in. Code 98016 will have a work RVU of 0.30, and the RUC recommended direct PE inputs have been finalized by CMS.

Non-Chemotherapy Administration – p. 298

Highlight: CPT guidelines and code definitions will be incorporated into Medicare operating manual to clarify coding for the provision of non-chemotherapeutic agents.

CMS finalized policy to update the Medicare Claims Processing Manual, chapter 12, section 30.5, that will modify the coding language to match CPT code definitions for complex non-chemotherapy infusion code series stating that the administration for certain of drugs and biologics may be considered complex and may be appropriately reported using the chemotherapy administration CPT codes 96401-96549. CMS believes that Medicare Administrative Contractors will now have the information needed to process claims appropriately for non-chemotherapy complex drugs and biologics.

In the 2024 proposed fee schedule rule, CMS requested comment on payment for non-chemotherapeutic complex drug administration services to address concerns that non-chemotherapeutic complex drug administration payment is inadequate due to existing coding and Medicare billing guidelines. Specifically, the agency wanted to know if there were “concerns for down coding or denials for the administration of non-chemotherapeutic infusion drugs.” Commenters supported the agency’s proposal stating that the CPT coding guidelines are sufficient to describe the services associated with the administration of drugs and biologics.

Request for Information for Services Addressing Health-Related Social Needs (Community Health Integration (G0019, G0022), Principal Illness Navigation (G0023, G0024), Principal Illness Navigation-Peer Support (G0140, G0146), and Social Determinants of Health Risk Assessment (G0136) – p. 213

Highlight: CMS thanks commenters for additional information but did not finalize new policy.

During last year’s rule making cycle, the agency proposed and finalized payment under the MPFS for services that address the health-related social needs of Medicare beneficiaries. These services included community health integration, principal illness navigation, principal illness navigation-peer support, and the provision of a social determinants of health risk assessment. The new services were created as part of the Biden administration’s plan to increase access to care in a fair and equitable manner. The agency requested additional information on ways to improve these services, address any care gaps that may not be covered by the new codes, and create additional codes within the scope of this policy. The agency simply thanked commenters and stated that comments will be taken into consideration if future rulemaking.

Strategies for Improving Global Surgery Payment Accuracy – p. 337

Highlight: CMS finalizes use of modifier -54 for both formal and informal transfers of care.

CMS proposed to broaden the applicability of the transfer of care modifiers -54 (surgical care only), -55 (post-operative management only), and -56 (preoperative management only. The agency believed the use of the transfer of care modifiers would provide data on how certain components of the surgical package are provided, who is performing the services, and which specialties are billing for services with the 90-day global period. The agency proposed the policy in the hopes that the use of the modifiers will prevent the duplicative Medicare payment for post-operative care given that the global payment would be adjusted based on the appended modifier.

However, and differing slightly from the proposed policies, CMS finalized that modifier -54 (surgical care only) is required to indicate instances for 90-day global surgical packages when a practitioner plans to furnish only the surgical procedure portion of the global package (including both formal and other transfers of care).” For modifiers -55 and -56, there are no policy changes, and those modifiers should be used only when there is a documented formal transfer of care.

CMS finalized the creation of HCPCS code G0559, an add-on code used to report services for post-operative care provided to a Medicare beneficiary by a practitioner that did NOT perform the surgical procedure. The code was created by the agency to capture the time and resources required in these cases. The code may only be appended to an office E/M service for new or established patients. Also, G0559 is only billable once during the 90-day global period. The final work RVU is 0.16. The complete description, along with the required elements of the new code may be found on page 740 of the display copy of the final rule.

Drugs and Biological Products Paid under Medicare Part B – p. 454

Requiring Manufacturers of Certain Single-Dose Container or Single-Use Package Drugs to Provide Refunds with Respect to Discarded Amounts

Recently, CMS finalized several policies to implement section 90004 of the Infrastructure Investment and Jobs Act, which requires manufacturers to provide a refund to CMS for certain discarded amounts from a refundable single-dose container or a single-use package drug for calendar quarters starting on January 1, 2023.

The agency finalized a modification to the regulatory text to revise how they determine the beginning of the 18-month exclusion period for certain drugs where the date the drug was first marketed (as reported to CMS) does not adequately approximate the first date of payment under Part B. In these cases, the first date where the drug is actually paid under Part B would be used to determine the start of the 18-month exclusion period.

CMS finalized the proposal to revise the definition of refundable single-dose container or single-use package drug to include injectable drugs with a labeled volume of 2 mL or less and that lack the package type terms and explicit discard statements in their product labeling, as well as to include drugs supplied in ampules.

Payment Limit Calculation when Manufacturers Report Negative or Zero Average Sales Price (ASP) Data

CMS finalized a methodology for calculating payment limits when manufacturers report negative or zero ASP data. The agency will consider that positive manufacturer’s ASP data is “available” while negative or zero ASP data is “not available” for CMS to calculate a payment limit. The agency sets out several calculations that depend on the following factors:

• Whether the drug is single source or multiple sources.
• Whether some, but not all National Drug Codes (NDCs) for a billing and payment code have a negative or zero ASP; or all NDCs for a billing and payment code have a negative or zero ASP; and
• Whether relevant applications to all NDCs for a billing and payment code have a marketing status of discontinued.

Appendix A: Specialty Level Impact Table