On July 8, the Centers for Medicare & Medicaid Services (CMS) filed the 2025 Medicare physician fee schedule and Quality Payment Program proposed rule, which includes potential revisions to payment policies under the physician fee schedule, quality payment program and other Medicare Part B payment policies. The AASM health policy team performed an analysis of the proposed rule, and the AASM responded to several proposals that would potentially impact sleep medicine care and reimbursement, if finalized. The AASM submitted a comment letter, in response to the rule, advocating on behalf of all members. Several key highlights are provided below.
The AASM responded to the following CMS proposals:
- 8% decrease in physician payments for 2025, with a conversion factor of $32.36
- Refinements in the current policy for services in 2025 to allow payment of the G2211 complexity add-on code, when the base code is reported by the same practitioner on the same day as an annual wellness visit, vaccine administration, or any other Part B preventive service in the office or outpatient setting
- Maintaining and/or extending several telehealth flexibilities, originally implemented during the COVID-19 public health emergency
- Establishment of three new G codes for reporting digital mental health treatment
- Revisions to MIPS performance thresholds
- Requests for information (RFI):
- Services associated with furnishing oral appliances used for the treatment of obstructive sleep apnea
- Building upon the MIPS value pathways framework to improve ambulatory specialty care
As CMS reviews all comments and prepares for publication of the 2025 final rule, AASM will continue to advocate for members to receive appropriate reimbursement for the delivery of high-quality care to patients with sleep disorders. Members may send questions about the proposed to coding@aasm.org.
