(Nov. 7, 2024) - On Nov. 1, The Centers for Medicare & Medicaid Services released the Final Rule of the Calendar Year 2025 Outpatient Prospective Payment System and the Final Rule of the CY 2025 Medicare Physician Fee Schedule. The Kansas Hospital Association has prepared a summary of the major provisions that can be viewed here. Both final rules institute significant updates, including new and updated Conditions of Participation, new quality measures and new codes for various services. These final rules provide substandard payment updates that do not adequately recognize the increasing costs hospitals and providers face on labor and supplies and the battle of emerging cybersecurity threats.
KHA will continue to advocate for critical congressional extenders and payment reforms to ensure Kansas hospitals receive appropriate reimbursement for care provided to Kansas communities while also working to improve the operating environment of providing patient care by removing unnecessary barriers and constraints.
OPPS Key Highlights Include:
- OPPS payment increase of 2.9 percent nationally.
- Payment adjustment of 7.1 percent for sole community hospitals.
- Reducing the time frame for prior authorization requests for outpatient department services from ten business days to seven calendar days for standard reviews.
- Add-on payment for non-opioid treatments for pain relief in the Hospital Outpatient Department.
Issued obstetrical services Conditions of Participation with phased implementation for hospitals and Critical Access Hospitals that provide obstetrical services.
- This includes new requirements for maternal quality assessment and performance improvement, as well as baseline standards for the organization, staffing, delivery of care within obstetrical units and staff training on evidence-based best practices every two years.
- Revised the emergency services CoP related to emergency readiness for hospitals and CAHs that provide emergency services.
- Revised the Discharge Planning CoP for all hospitals related to transfer protocols.
- New Medical Clinic Services’ Four Walls exceptions for rural and behavioral health clinics.
- Quality Updates:
- Finalized new measures in Outpatient Quality Reporting, Rural Emergency Hospital Reporting and Ambulatory Surgical Quality Reporting programs.
- Removed two measures from the OQR Program.
- Will publicly report the Median Time from Emergency Department Arrival to ED Departure for Discharged ED Patients Measure – Psychiatric/Mental Health Patients stratification on Care Compare beginning with CY 2025.
- Narrowing the definition of “custody” in Medicare’s payment exclusion rule and revising the Medicare special enrollment period for formerly incarcerated individuals.
MPFS Key Highlights Include:
- Reduction of average payment rates by 2.93 percent.
- Continuation of various telehealth flexibilities, including:
- Extending services on the Medicare Telehealth Services List.
- Allowing the utilization of audio-only technology for telehealth services furnished to beneficiaries in their homes and
- Direct supervision is permitted through the supervising practitioner, who is immediately available through real-time audio and visual interactive telecommunications.
- Creation of new Advanced Primary Care Management Services codes.
- Establishes new coding and payments for various behavioral health services.
- Allows for general supervision of Physical Therapy Assistants and Occupational Therapy Assistants by PTs or OTs in private practice for all applicable physical and occupational therapy services.
- Various updates related to Rural Health Clinics, including new care coordination codes, telehealth flexibilities and payment for preventive vaccine costs.
- CMS will no longer determine or enforce the standard of RHCs being primarily engaged in furnishing primary care services and will no longer consider the total hours of an RHC’s operation and whether a majority that is more than 50 percent of those hours involve the provision of primary care services through the survey process.
Unless otherwise noted, provisions will go into effect on Jan. 1, 2025.
KHA encourages Prospective Payment System hospitals to log in to Advantage Analytics to view their hospital-specific impact reports. If you need a reminder of your login information, please get in touch with KHA.