For the fifth straight year, physicians are facing a cut in Medicare payment—it’s 2.83% in 2025—after Congress failed to take action to stop it. And only Congress can move to prevent the severe limitations on telehealth that existed before the COVID-19 pandemic from being put back in place. As part of the government-funding deal brokered before Christmas, these temporary telehealth flexibilities were extended until March of this year when the continuing resolution expires and Congress again will be faced with the need to act.
But Lindsey Baldwin and Emily Yoder, the director and deputy director of the Centers for Medicare & Medicaid Services’ Division of Practitioner Services were able to detail some steps they were empowered to take to support primary care and vaccination during a presentation at the 2025 AMA CPT and RBRVS Annual Symposium, held virtually in November.
Yoder noted that while it was up to Congress to retain the regulatory flexibilities that enabled telehealth to flourish during the COVID-19 public health emergency and there after, her agency’s “final rule does reflect CMS’ goal to preserve some important but limited flexibilities in our authority and expand the scope of an access to telehealth services where appropriate.”
CMS has finalized expanding the Medicare telehealth services list to include caregiver-training services on a provisional basis and HIV prep counseling.
CMS will continue to suspend frequency limitations for subsequent inpatient visits, subsequent nursing facility visits and critical care consultations for 2025.
Starting Jan. 1, the CMS definition of an “interactive telecommunication system” may include two-way, real time audio-only communication technology for any Medicare telehealth service furnished to a beneficiary in their home if the distance site physician or nonphysician practitioner is technically capable of using an interactive telecommunication system but the patient is not capable of or does not consent to the use of video technology.
“We are also finalizing that—through calendar-year 2025—we will continue to permit distant-site practitioners to use their currently enrolled practice locations instead of their home addresses when providing services from their home,” Yoder said.
Through 2025, CMS will allow teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in all teaching settings, Yoder said.
One example of how this would work, she explained, would be a three-way telehealth visit with the patient, resident and teaching physician in separate locations.
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Recognizing primary care’s value
In her presentation, Yoder also noted that CMS has finalized its proposed “outpatient office evaluation and management (complexity add-on)” code. It would be part of the CMS Healthcare Common Procedure Coding System (HCPCS), G2211, and add on to AMA Current Procedural Terminology (CPT®) codes 99202–99205, and 99211–99215.
The add-on code would be used to when the CPT codes are reported by the same practitioner on the same day as an annual wellness visit, vaccine administration, or any Medicare Part B preventive service, including the initial preventive physical examination, furnished in the office or outpatient setting.
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“A strong, foundational primary care system is fundamental to improving health outcomes, lowering mortality, and reducing health disparities, which is why the Department of Health and Human Services has been taking action to strengthen primary care, including establishing coding and payment for advanced primary care-management services,” Yoder said.
The CMS Comprehensive Primary Care Plus program was also reviewed in a separate presentation by Peter Hollmann, MD, a past chair of the CPT Editorial Panel, who praised the benefits to practices providing these key services.
This CMS effort “really recognizes the resources that are required to provide advanced primary care,” Dr. Hollmann said. “It allows some predictable payment so that people can hire the additional staff and pay for the work of team-based care.”
What’s in a name
One change that was highlighted during the symposium’s primary-care presentation involved a new name for the Vaccine Coding Caucus. It is now the “Immunization Coding Caucus.”
The name change reflects a desire to cover all methods of immunization and the inclusion of immune globulins in the CPT Editorial Panel’s early release policy. The policy involves the rapid release of immunization codes to meet urgent public health needs.
Last year, for example, the early release process facilitated earlier access to code 90684, developed to report administration of pneumococcal conjugate vaccine, 21 valent. It was early released on the AMA website last May and became effective less than a month later.
Code 90695 was early-released last July and will be used for influenza virus vaccine, H5N8, pending Food and Drug Administration (FDA) approval.
Two codes recently added and first published in the 2025 code set are 90637 and 90638 for an mRNA quadrivalent vaccine targeting influenza; and were given emergency use authorization by the FDA.
Code 90637 is recommended for patients 18–64 years old.
Code 90638 is for a higher dose that is recommended for patients 65 or older.
Other immunization-related updates to the CPT code set for 2025 involve the deletion of codes 90654 and 90630 because the influenza vaccines they described are no longer in use.
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