The Proposed 2025 Medicare Physician Fee Schedule Has Arrived!
Here’s what’s in it—and what’s not—for Remote Patient Monitoring, Chronic Care Management and Primary Care.
The 2025 Medicare Physician Fee Schedule Proposed Rule (the “2025 Proposed Rule”) issued by the Centers for Medicare and Medicaid Services (CMS) on July 10, 2024, contains several new policy proposals with significant implications for healthcare innovators.
Here is an overview of the most significant proposals and the opportunities they present for healthcare innovators and digital health companies.
New “Advanced Primary Care Management” HCPCS Codes
The most surprising proposal by CMS involves a completely new approach to care management services in a primary care setting. CMS has created three new Advanced Primary Care Management (APCM) HCPCS codes (GPCM1, GPCM2, and GPCM3) to emphasize comprehensive and accessible care management services, delivered through the patient’s preferred method.
The new codes bundle elements of the existing Chronic Care Management (CCM) and Principal Care Management (PCM) codes with Communications Technology-Based Services (CTBS) codes for virtual check-ins, remote evaluation of images, e-visits, and interprofessional consults to create an “enhanced care management” bundle. Unlike CCM and PCM services, the APCM codes are not time-based, meaning care management services that do not meet the 20 or 30-minute requirements for CCM or PCM would be billable under APCM. However, CCM and PCM would not be able to be billed concurrently with APCM.
Of note, practices will still be able to bill Remote Physiological Monitoring (RPM) concurrently with APCM.
New Reimbursement Construct for Care Management Services in FQHCs and RHCs
The 2024 Physician Fee Schedule added Remote Physiologic Monitoring and Remote Therapeutic Monitoring services to the list of care management services billable by FQHCs and RHCs under HCPCS G0511. For 2025, CMS proposes to allow RHCs and FQHCs to use existing care management CPT codes for each service encompassed in G0511, including the proposed APCM codes if finalized. Payment will be at the national non-facility payment rate and would still be in addition to the RHC AIR or FQHC PPS rates.
This seems to be good news for FQHCs who want to add RPM to their practice, as the potential reimbursement for relevant RPM CPT codes is higher than the proposed G0511 rate from last year. However, stakeholders should be aware that it could result in a reduced rate for some of the services encompassed in the combined G0511.
ASCVD Risk Scores
Beginning in 2025, CMS is proposing coding and payment for Atherosclerotic Cardiovascular Disease (ASCVD) risk assessment service and risk management services. The ASCVD risk assessment would be performed in conjunction with an E/M visit, when a provider identifies a patient who is at-risk for CVD but does not have a diagnosis. The standardized risk assessment tool must yield a 10-year estimate of the patient’s ASCVD risk.
In addition, CMS is proposing coding and payment for ASCVD risk management services related to the ABCs of CVD risk reduction like blood pressure management and cholesterol management.
Rimidi’s Cardiovascular View not only automatically calculates a patient’s ASCVD risk score based on clinical data in the EHR, but also enables clinicians to intervene with guideline-based management based on data from the EHR or patient-generated data from a connected blood pressure cuff.
What about Remote Patient Monitoring?
Notably, there were no sweeping changes to RPM codes in the 2025 Proposed Rule, but experts expect these to come in 2026. Despite no coding changes specifically for RPM, CMS has once again signaled with topics like APCM and ASCVD coding that RPM is a means to an end, and the coding is simply a way to bridge healthcare to more sustainable, outcomes-focused care that programs like RPM help enable.
Further, pulling the RPM CPT codes out from the G0511 code should enable more FQHCs and RHCs to build and sustain an RPM program for their underserved patient populations.
CMS will accept public comments on the proposals until September 9, 2024. More information about all the proposed changes can be found in the PFS fact sheet.
Rimidi’s Platform is Designed to Meet Clinical and Billable Requirements
Rimidi enables better chronic disease management with Remote Patient Monitoring and risk stratification capabilities. By combining patient-generated health data from connected devices with clinical data from the EHR, Rimidi’s platform drives patient-specific clinical insights and actions, while capturing all clinical and billable documentation.
