How Will the 2025 MPFS Impact Your Practice?

New payment policy, coding, and reimbursement changes set forth in the calendar year (CY) 2025 Medicare Physician Fee Schedule (MPFS) final rule took effect on January 1. The MPFS, which the Centers for Medicare & Medicaid Services (CMS) updates annually, lists payment rates for Medicare Part B services and introduces or modifies other regulations that affect physician reimbursement and quality measurement.

The ACS submitted comments on September 9, 2024, in response to the CY 2025 MPFS proposed rule issued by CMS earlier in the year.¹ Some provisions in the final rule, released November 1, 2024, incorporate the College’s recommendations.² Although the final rule includes important policy changes that impact all physicians, this article focuses on those that are particularly relevant to general surgery and its related subspecialties.

Global Surgery Payment

Transfer of Care Modifiers

As part of CMS’s ongoing efforts to gather data to revalue global codes, CMS broadened the applicability of the transfer of care modifier, modifier -54 (Surgical Care Only). CMS finalized a proposal for modifier -54 to apply to all 90-day global surgical packages in any case in which a surgeon expects to furnish only the surgical procedure portion of the global package, including, but not limited to, when there is a formal, documented transfer of care as under current policy, or an informal, nondocumented but expected, transfer of care. Specifically, modifier -54 should now be appended in all instances when a surgeon only intends to perform the procedure and does not anticipate providing postoperative care or follow-up visits.

The ACS has expressed concern about CMS’s various global codes data collection strategies in the past and has stressed that any changes to global codes must only be made using accurate, complete, and actionable data. This year, we commented that CMS’s expansion of the use of the transfer of care modifier to include informal, nondocumented transfers of care will not result in meaningful information about the care that surgeons are providing in the postoperative period, and therefore should not be used to revalue global codes.

Postoperative Care Services Add-On Code

CMS established separate payment for add-on code G0559 to account for postoperative care if furnished by someone other than the operating surgeon. CMS believes that there are instances in which someone other than the operating surgeon, such as a primary care physician or someone in a different group practice, provides follow-up care despite there being no formal transfer of care. The agency expects this add-on code to be reported with an office or other outpatient evaluation and management (E/M) visit and finalized the following code descriptor for G0559:

Postoperative follow-up visit complexity inherent to evaluation and management services addressing surgical procedure(s), provided by a physician or qualified health care professional who is not the practitioner who performed the procedure (or in the same group practice) and is of the same or of a different specialty than the practitioner who performed the procedure, within the 90-day global period of the procedure(s), once per 90-day global period, when there has not been a formal transfer of care and requires the following required elements, when possible and applicable:

Reading available surgical note to understand the relative success of the procedure, the anatomy that was affected, and potential complications that could have arisen due to the unique circumstances of the patient’s operation
Research the procedure to determine expected postoperative course and potential complications (in the case of doing a postop for a procedure outside the specialty)
Evaluate and physically examine the patient to determine whether the postoperative course is progressing appropriately
Communicate with the practitioner who performed the procedure if any questions or concerns arise (List separately in addition to office/outpatient E/M visit, new or established)

This add-on code was also part of CMS’s attempts to gather data for revaluing global codes. The ACS commented that surgeons typically provide postoperative care to their own patients. If they are unable to do so, they formally transfer care to another surgeon. Therefore, this add-on code is unlikely to gather useful information for revaluation of global codes. Our comments also noted that the code descriptor does not distinguish between surgical postoperative visits and visits unrelated to surgery. This lack of clarity could lead to misuse of the code and to duplicative payment.

Table. Calculation of the 2025 MPFS Conversion Factor

Valuation of Surgical Services

The ACS made numerous recommendations to CMS regarding new or revised values for surgical Current Procedural Terminology (CPT)* codes for CY 2025, including those for intra-abdominal excision or destruction of tumors or cysts, skin cell suspension autograft, and others. To learn more, see “New 2025 CPT Coding Presents Changes for General Surgery, Related Specialties.”

Colorectal Cancer Screening Coverage

The agency expanded coverage for colorectal cancer (CRC) screening to include computed tomography colonography and blood-based biomarker CRC tests. In instances where either of such screening methods produce a positive result, patients are eligible for a follow-on screening colonoscopy with no additional beneficiary cost-sharing. To reflect current evidence-based clinical standards for CRC screening, the agency removed coverage for the barium enema procedure, which is no longer recommended as an appropriate CRC screening test given the advancement of alternatives.

ACS advocacy efforts have successfully led to numerous improvements in CRC screening policies over the last several years, such as reducing the age limitation for Medicare screening coverage from age 50 to 45; eliminating coinsurance for follow-on colonoscopies after noninvasive stool-based tests yield positive results; and phasing out beneficiary cost-sharing for CRC services that are planned as screening tests but become diagnostic tests when the physician identifies the need for additional treatment (such as removal of polyps) in the same clinical encounter.

Calculation of the 2025 MPFS Conversion Factor

Absent Congressional intervention, the 2025 MPFS conversion factor (CF)—which is the amount Medicare pays per relative value unit—is $32.3465, an approximate 2.83% decrease from last year’s CF of $33.2875. The 2025 MPFS CF reflects the expiration of temporary assistance provided by the Consolidated Appropriations Act (CAA) 2024 (see Table, above).

Lauren Foe is the Senior Associate for Regulatory Affairs, Kate Murphy is the Regulatory and Quality Assistant, and Vinita Mujumdar is Chief of Regulatory Affairs in the ACS Division of Advocacy and Health Policy in Washington, DC.