2025 Medicare Physician Fee Schedule Proposed Rule – Pathology 

By:
Liz Hansard, CPC, COC; Vice President of Pathology and 

Lisa Warren, CHC; Director of Pathology Client Services

The Proposed 2025 Medicare Fee Schedule (MPFS) was published on July 10, 2024 and stakeholders have until September 9th to submit public comments. The proposed conversion factor for Calendar Year (CY) 2025 is $32.35, representing a 2.4% decrease from the 2024 pathology fee schedule. The reduction is largely due to budget neutrality requirements mandating decreases in payments that were previously delayed by Congressional action. Payments for pathology have experienced an overall decrease of 7% since 2021.

Background

Since January 1, 1992, Medicare payments have been made under the Medicare Physician Fee Schedule (MPFS) for physician services. Payments are based on the relative resources typically used to furnish these services and these relative value units (RVUs) are applied to each service for work, practice expense, & malpractice expense. RVUs become payment rates through the application of a conversion factor and geographic adjusters (geographic practice cost indices – “GPCIs”) are also applied to the total RVUs to account for cost variations by geographic area.

A Peek at the Impact

MSN Healthcare Solutions reviewed the top tier (by volume) of pathology codes so practices can begin to estimate the financial impact of the proposed fee schedule. (See table below)

Medicare Proposed Changes

2025 Medicare Physician Fee Schedule Proposed Rule - Medicare Proposed Changes

MIPS

We anticipate it will be more difficult for pathology practices to avoid payment penalties and will provide more specific comments later this year once new performance measures are approved.

Under the proposed fee schedule, CMS plans to maintain the performance threshold at 75 points as well as keeping the data completeness threshold at 75 points.

MSN will provide each pathology client with a projected impact analysis once the Medicare Physician Fee Schedule final rule is published.

If you have any questions or wish to discuss this information further, please contact MSN Director of Pathology Client Services, Lisa Warren at Lisa.Warren@msnllc.com or (573) 590-1418.

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