What the CMS 2025 PFS Proposed Rule Means for Virtual Care

What the CMS 2025 PFS Proposed Rule Means for Virtual Care

The Centers for Medicare & Medicaid Services (CMS) issued its 2025 Physician Fee Schedule (PFS) proposed rule earlier this month. Alongside a 2.8 percent payment cut for physicians, the rule includes numerous proposals directed at virtual care, including brand new codes for certain digital therapeutics solutions.The proposed rule provides several wins for telehealth proponents; however, these wins may be moot if Congress fails to extend pandemic-era telehealth flexibilities beyond 2024. In 2022, Congress passed a $1.7 trillion spending bill that extended telehealth waivers — including ones that eliminated restrictions on originating sites for telehealth services and allowed federally qualified health centers (FQHCs) and rural health centers (RHCs) to continue receiving telehealth reimbursement under Medicare — until December 31, 2024.As the virtual care industry awaits the final word from Congress, the CMS proposed rule can be viewed as cautiously optimistic for stakeholders. However, it also reveals pitfalls in current approaches to paying for virtual care services.

Medigy Insights

Aside from the new digital therapeutics codes, the provisions in the 2025 PFS proposed rule that affect virtual care are largely continuations from previous PFS rules.For instance, CMS plans to continue allowing distant site practitioners to use their practice location instead of their home address when providing telehealth services and allowing teaching physicians to virtually supervise residents who are providing telehealth services in teaching settings.Additionally, the agency proposed permanently adopting a definition of direct supervision that allows the physician to provide such supervision through real-time audio and visual telecommunications, permanently changing the definition of an interactive telecommunications system to include audio-only, and temporarily allowing payment for non-behavioral health visits furnished via telecommunication technology at FQHCs and RHCs. 


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