Academy Analysis: Medicare Physician Fee Schedule 2025

The Centers for Medicare & Medicaid Services has released its final rule for the Medicare Physician Fee Schedule for 2025. Here are highlights based on the Academy’s early analysis.

2024 vs. 2025 Comparison Tables

Final 2025 Fee Schedule Reduces Pay to Physicians by 2.8%

The Centers for Medicare & Medicaid Services (CMS) has released its final Medicare Physician Fee Schedule for 2025. Here are the highlights, based on the Academy’s analysis. The Academy is working with partner societies, the American Medical Association (AMA), the American College of Surgeons, and Congress, advocating for relief from a payment cut.

The final 2025 fee schedule has an estimated 2.8% reduction to Medicare payments, which reflects the expiration of two conversion factor boosts previously provided by Congress.

Conversion factor changes affect each specialty differently, and ophthalmology faces a nearly 5% cut to Medicare payments for the coming year. The effect on individual ophthalmologists will be determined by the mix of procedures they perform.

The Academy will continue its work with the AMA and the Surgical Coalition to press Congress to prevent these cuts and to develop a Medicare physician payment system that is rational and sustainable. We need your help! Urge your members of Congress to act before the end of the year to stop these devastating cuts.

2025 Conversion Factor

The 2025 conversion factor is $32.35, a decrease of $0.94 (2.8%) from the ending 2024 Medicare Physician Fee Schedule conversion factor of $33.29. Of note, there are two conversion factors for 2024. For dates of service Jan. 1 through March 8, 2024, the conversion factor is $32.74. Beginning March 9 through Dec. 31, 2024, the conversion factor increased to $33.29 following passage of the Consolidated Appropriation Act, 2024.

Global Surgical Codes

The Academy has steadfastly pushed for payment equity for post-operative visits bundled into global surgical codes. We are disappointed that CMS did not offer a fix in the final rule. Instead, the agency has finalized two policies aimed at collecting more data on global surgical code payment accuracy.

Despite opposition from the Academy and other stakeholders, CMS finalized a requirement to use transition of care modifier (-54) for all 90-day global surgical packages when a practitioner (or group practice) expects to furnish only the procedure portion of a global package, whether or not the transfer of care is formally documented. Global codes with these modifiers are paid at lower rates.

CMS also finalized a new add-on HCPCS Level II code, G0559, for post-operative care services by practitioners who were not involved in performing the surgical procedure. In response to stakeholder feedback, they are modifying the criteria so that it may be billed by a practitioner of the same specialty as the proceduralist as long as they are not in the same group practice. Effective Jan. 1, 2025, the work RVU value for G0559 is 0.16. Although many stakeholders shared concerns about the validity of the claims data to be collected with these policies, the agency plans to use the modifier and add-on code claims data to inform future policymaking on global surgical payments. The Academy will continue working with the Surgical Coalition to explore new strategies to advocate for global post-op visit payment equity.

Specific CPT Code Valuations

New Iris Prosthesis Code 66683

Effective Jan. 1, 2025, Category I CPT code, 66683 will be available for “implantation of iris prosthesis, including suture fixation and repair or removal or iris, when performed.” The new permanent code replaces the temporary 0616T, 0617T, and 0618T Category III CPT codes, which were not valued by the RUC. This update also resulted in the revaluation of the existing iris prosthesis procedure family.

After urging CMS to reconsider its unacceptable proposal and implement the Relative Value Update Committee (RUC)-recommended work values for CPT 66680, 66682, and 66683, we are disappointed that the agency finalized the values as proposed.

66680: 7.97 WRVUs, up 1.58 WRVUs from the current value of 6.39 WRVUs
66682: 8.74 WRVUs, up 1.41 WRVUs from the current value of 7.33 WRVUs
66683: 10.67 WRVUs

Although it’s an increase for each existing code, we are disappointed that CMS did not accept our evidence supporting the intensity of the procedures warranting the higher WRVUs recommended by the RUC.

New Retina OCT Angiography Code 92137

Effective Jan. 1, 2025, Category I CPT code, 92137 will be available for “optical coherence tomography (OCT) of the retina, including OCT angiography.” This unfortunately accompanied the revaluation of the existing OCT procedure family.

CMS accepted and finalized the RUC’s recommendations for each of these codes:

92132: 0.29 WRVUs, down 0.01 from the current value of 0.30 WRVUs
92133: 0.31 WRVUs, down 0.09 from the current value of 0.40 WRVUs
92134: 0.32 WRVUs, down 0.13 from the current value of 0.45 WRVUs
92137: 0.64 WRVUs, affirming the Academy’s recommendation to RUC

Strabismus Surgery CPT Codes 67331 & 67334

CMS will continue to phase-in cuts to two strabismus add-on codes that were reduced more than 20% in the 2022 fee schedule. This will result in the following changes to total RVUs:

+67331 (prior eye surgery add on): 3.73 total RVUs, down from the 2024 total RVUs of 4.61
+67334 (posterior fixation suture technique add on): 3.68 total RVUs, down from the 2024 total RVUs of 4.54

Medicare Economic Index Rebasing and Revising

For 2025, CMS will continue delaying implementation of the policies from the 2023 final rule that would have rebased and revised the Medicare Economic Index (MEI) calculation for practice expenses. This delay is intended to allow time for the agency to review the results of the 2024 AMA Physician Practice Expense Survey, compare this dataset against other potential data sources for rebasing the MEI, and to solicit public comment.

Quality Payment Program and MIPS Changes

As a result of relentless advocacy from the Academy and the physician community, CMS finalized keeping the 2025 performance threshold at 75 points. This will provide much-needed stability in the MIPS program as it continues to become more rigorous. As required by statute, CMS also finalized keeping the performance category weights unchanged: cost performance 30%; quality performance 30%; improvement activity 15%; and promoting interoperability 25%.

Updated Scoring Methodologies

The Academy applauds CMS for finalizing the following scoring methodology changes, which will help to boost scores and reduce burdens for many physicians who participate in MIPS:

Improvement activities (IA). CMS finalized the removal of weightings for IAs (high-weighted vs. medium-weighted). Instead, each IA will be worth 20 points, and 40 points for small or rural practices. Physicians must score 40 points to achieve the maximum score in this performance category.
Cost category. CMS finalized a new cost scoring methodology, where the median cost for a measure will be set at the performance threshold for the MIPS payment year (e.g., 7.5/10 for the 2024 performance year/2026 payment year). This will take effect when 2024 final scores are released in summer 2025. The Academy supports this change as it will improve cost performance scores for many physicians, particularly those who score at or near the median cost. This update is the result of persistent advocacy from the Academy and the physician community who have pushed to correct flaws in the previous scoring system.

Specialty Measures Sets

CMS has finalized the creation of separate specialty measure sets of MIPS quality measures for ophthalmology and optometry. The agency originally revised the specialty measure set for the 2023 performance year to combine ophthalmology and optometry to ophthalmology/optometry. However, many measures in the combined set applied only to ophthalmologists.

We are pleased that the agency responded to our concerns about the risks of combining the two specialty measure sets, which could have encouraged providers to report on treatments outside their expertise, licensure, or experience.

Improvement Activities

We are disappointed that CMS is removing the following improvement activities for the 2025 performance year/2027 payment year, which have played an important role in improving patient care and are commonly reported by ophthalmologists. We will continue to advocate that practices should retain the flexibility to choose activities that best fit their practice and patients' needs.

Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient's Medical Record
Implementation of a Personal Protective Equipment (PPE) Plan
Implementation of a Laboratory Preparedness Plan
Invasive Procedure or Surgery Anticoagulation Medication Management

Beginning with the 2026 performance year and the 2028 payment year, the following activities will be removed:

Population Empanelment
Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop
Implementation of Improvements That Contribute to More Timely Communication of Test Results
Electronic Health Record Enhancements for Behavioral Health (BH) Data Capture

MIPS Value Pathways (MVPs)

We are deeply disappointed that CMS has not made a good faith effort to incorporate our feedback and has finalized a comprehensive MVP for ophthalmology including all subspecialists, titled “Complete Ophthalmologic Care,” which will be available for voluntary reporting for the 2025 MIPS performance year/2027 payment year. The Academy and our ophthalmology subspecialty partners have persistently advocated against a one-size-fits-all MVP, as the limited subset of quality measures, improvement activities, and cost measures would not allow many ophthalmic subspecialists to succeed in the program.

CMS recently sought feedback on MVP readiness and has identified the 2029 performance year/2031 payment year as the potential timeline for sunsetting traditional MIPS and making MVP reporting mandatory. We will continue to advocate that physicians should have the flexibility to choose between participating in either an MVP or the traditional MIPS pathway, ensuring they can select the measures most appropriate for their practice and patient population.

Cataract Surgery Cost Measure

CMS has finalized significant changes to the Cataract Removal with Intraocular Lens (IOL) Implantation Measure for the 2025 MIPS performance year/2027 payment year, which remains the only cost measure specific to ophthalmology.

Academy staff will be conducting a detailed analysis of these changes and will provide an update to members in the Academy’s Washington Report Express.

Health IT Vendors

Starting with the 2025 performance year/2027 payment year, CMS will no longer allow Health IT vendors to submit data on behalf of MIPS eligible clinicians. Any vendor who plans to submit MIPS data must self-nominate as either a qualified registry (QR) or qualified clinical data registry (QCDR). If you are currently reporting for MIPS through a Health IT vendor, check if your vendor plans to self-nominate as a QR or QCDR for the 2025 performance year/2027 payment year.

CMS has designated the Academy’s IRIS® Registry (Intelligent Research in Sight) as a QCDR since 2015. With these changes, the IRIS Registry will remain ophthalmologists’ best tool for success and has enabled participants in the past to perform well in MIPS, cumulatively avoiding over $1 billion in penalties.

Participating is easy: The IRIS Registry calculates the quality measures from the data in your electronic health records (EHR) system and submits the relevant data to CMS. If you don’t have an EHR system, the IRIS Registry also continues to offer a way to manually report.

View the CMS press release for the final rule.

More Analysis Coming

The Academy continues to analyze this significant rule. Read Washington Report Express in coming weeks for more information on how this final rule may affect our profession.

For more information, contact healthpolicy@aao.org.