AAMC Comments on CY25 Physician Fee Schedule and Quality Payment Program Proposals

The AAMC submitted comments (PDF)to the Centers for Medicare & Medicaid Services (CMS) on Sept. 9 in response to the calendar year (CY) 2025 Physician Fee Schedule and Quality Payment Program (QPP) proposed rule [refer to Washington Highlights, July 12].

The CMS proposed a conversion factor of $32.36, a 2.8% reduction from the 2024 conversion factor. In previous comments the association encouraged the agency to support legislation that would provide an annual inflation-based payment update to physicians based on the Medicare Economic Index.

The AAMC urged the CMS to ensure appropriate payment for telehealth services, extend COVID-19 telehealth flexibilities where the CMS has the authority to do so, and support legislative efforts by Congress to extend access to telehealth services beyond rural areas and within patients' homes. The association's comments also supported expanding the primary care exception to improve access to care and increase training opportunities for residents.

Specific to the QPP, the AAMC's comments recommended that the CMS work with key invested parties to identify longer term policy solutions that would bolster quality, achieve health equity for all beneficiaries, improve patient outcomes, and reduce burden. Comments also responded to numerous proposals to modify policies for the Medicare Shared Savings Program and a request for information from the Innovation Center to inform design of a new ambulatory specialty care model.