ASA Opposes Payment Cuts Proposed by CMS for 2025

Today, ASA submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the agency's CY 2025 Medicare Physician Fee Schedule proposed rule. ASA expressed strong opposition to significant payment cuts to physicians, including anesthesiologists, and provided detailed feedback on other wide-ranging payment and quality regulations.

ASA's comments reiterated our past calls for CMS to work with Congress on addressing underlying flaws of the Medicare Part B payment system. In particular, ASA supports legislative changes to address outdated budget neutrality requirements and encourages Congress to implement an inflation adjuster for physicians participating in Medicare Part B. On other proposed policies, ASA urged CMS to finalize its CPT codes, advocated for the availability of telemedicine codes for pre- and post-operative services, and supported efforts to refine practice expense methodology.

ASA was pleased that CMS aligned with ASA's support for the valuation and payment for fascial plane blocks. ASA's comments also expressed that CMS should recognize complex patients receiving anesthesia services and appropriately compensate anesthesiologists for these additional services as the work values of complex care are not captured by the standard anesthesia CPT codes.

On the Quality Payment Program, ASA commended CMS for maintaining the existing Merit-based Incentive Payment System (MIPS) performance threshold at 75 points as well as the data completeness threshold for quality measures at 75%. ASA's advocacy work on topped out measure status is beginning to see success as CMS proposed removing the 7-point cap for anesthesiology MIPS measures. ASA encouraged CMS to also remove the topped-out cap for Qualified Clinical Data Registry (QCDR) anesthesiology measures. ASA has been a national leader in MIPS Value Pathways (MVPs) and suggested CMS consider supporting multispecialty MVPs. ASA provided detailed comments on a request for information regarding a potential ambulatory care specialty model.

Final regulations will be issued on or around November 1, and unless otherwise noted, policies will be effective January 1, 2025.

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].

More resources:

• ASA Washington Alert on CY 2025 proposed rule
• Proposed rule (PDF)
• CMS press release on proposed rule
• QPP fact sheet