MPFS Rule Summary

Dear RHC Community,

On July 10th, the Centers for Medicare and Medicaid Services (CMS) issued the CY 2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule. This year’s 2,248 page rule, contains several Rural Health Clinic (RHC) specific policy proposals, as well as other provisions with implications for the RHC community, including:

• Allowing RHCs to bill for administration of Part B preventive vaccines at time of service, not entirely in a lump sum settlement on cost report
• Elimination of RHC productivity standards
  Complete revision to RHC care management billing with the elimination of the G0511 consolidated code
  • Establishment of new “Advanced Primary Care Management Services”
• Modification of specific lab services RHCs must have the ability to furnish within the facility
• Aims to clarify guidance versus regulatory discrepancies in how “primarily engaged in primary care” is defined and enforced
• Seeks to define “mental diseases” to support RHCs that offer behavioral health services within the confines of outdated statutory language
• Clarification of dental services able to be furnished in RHC setting
• Modified Intensive Outpatient Program (IOP) Services payment, a new billable service in the RHC beginning January 1, 2024
• Telehealth policy clarifications within CMS’ authority (the majority of Medicare telehealth policy extending past December 31, 2024 relies on Congressional action)

“In terms of the sheer number of substantial updates to the Rural Health Clinics program, this has been the biggest proposed rule in at least ten years,” said Nathan Baugh, Executive Director of NARHC. “While we always have more work to do when it comes to clarifying and updating regulations, and there are some things we asked CMS to address that were not included in this rule, many of these proposed changes are huge steps forward for the RHC program and we thank CMS for listening to Rural Health Clinic concerns over the years.”
If these policies are finalized by CMS this November, they would go into effect January 1, 2025, unless otherwise specified. While quite comprehensive, we encourage you to read the entirety of this article on NARHC.org in order to understand the RHC-relevant provisions and NARHC’s perspectives on this year’s proposals!
Additionally, we encourage you to join our Washington, D.C. team for a webinar on August 15, 2024, where we will discuss the proposed rule and hear your feedback about implementation of these various policy proposals. Please register for the webinar and submit any questions you would like addressed during the webinar here.
Please contact Sarah Hohman, NARHC Director of Government Affairs at [email protected] with any questions or other feedback.