MGMA comments on 2025 Medicare Physician Fee Schedule proposals (September 9, 2024)

September 9, 2024 

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Re: Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments [CMS-1807-P]

Dear Administrator Brooks-LaSure:

The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the calendar year (CY) 2025 Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule, published in the Federal Register on July 30, 2024.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups comprising more than 350,000 physicians. These groups range from small independent practices in remote and other underserved areas to large regional and national health systems that cover the full spectrum of physician specialties.  

Key Recommendations

MGMA appreciates the Centers for Medicare & Medicaid Services’ (CMS) leadership in overseeing the Medicare program and working to make improvements for patients and providers. We respectfully offer the following comments in response to the CY 2025 PFS proposed rule. CMS should:

• Work with Congress to provide a positive update to the Medicare conversion factor in CY 2025 and all future years. MGMA remains deeply concerned with the estimated reduction to the CY 2025 conversion factor and its impact on medical group practices. Conversion factor cuts over the past five years have compounded well-documented administrative and financial pressures facing medical groups. These ongoing cuts coupled with a lack of an inflationary update further exacerbate these issues and undermine the ability of physician practices to provide high-quality care — the current situation is untenable and must be remedied immediately.

• Work with Congress to extend telehealth flexibilities past the end of 2024 while utilizing its full statutory authority to permanently cover telehealth services. Medical groups continue to utilize telehealth services to best serve their patients — access to care will be significantly impacted if the current policies in place such as geographic and originating site flexibilities are not extended.

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