Understanding the Wound Care Impacts from the CY 2025 Medicare Physician Fee Schedule

The CMS updates to the Physician Fee Schedule (PFS) for CY 2025 reflect ongoing efforts to adapt to evolving healthcare needs, particularly in wound care. Among these changes, CMS is focusing on caregiver training for wound management and proposing adjustments in the payment structures for skin substitutes and telehealth services. These updates are part of a broader strategy to enhance the quality of care while addressing the financial aspects of wound care services. Providers should stay informed to navigate these shifts effectively.

Conversion Factor and Payment Adjustments

Average payment rates under the PFS are proposed to decrease by 2.93% in CY 2025. This is compared to the average payments for most of CY 2024. The adjustment to the PFS conversion factor includes a 0.00 percent overall update mandated by law. It also includes the expiration of the 2.93% payment increase for CY 2024. A minor estimated adjustment of 0.05% is due to changes in work relative value units (RVUs) for certain services. This results in a proposed CY 2025 PFS conversion factor of $32.36. This is a reduction of $0.93 (or 2.80%) from the current CY 2024 conversion factor of $33.29.

Although this decrease might seem significant, similar adjustments have occurred in previous years:

  • CY 2024: Reduced by 3.3% from CY 2023.
  • CY 2023: Reduced by 4.5% from CY 2022.
  • CY 2022: Reduced by 3.75% from CY 2021.
  • CY 2021: Increased by 3.3% from CY 2020.

While the current reduction requires operational adjustments, it is part of a broader trend in Medicare payment policy.

Caregiver Training Services (CTS)

CMS is proposing new coding and payment for caregiver training services. These include techniques for preventing decubitus ulcers and wound dressing changes. This could enhance care quality by ensuring caregivers are better equipped to manage wound care at home. It may also reduce hospital readmissions.

Skin Substitutes and Biologicals

CMS continues to exclude skin substitutes from the refund policy for discarded amounts of single-use drugs. However, ongoing evaluations may lead to future changes in payment structures for skin substitutes. This could affect cost management strategies for wound care providers. Additionally, CMS is still developing a consistent payment approach for services across different Site of Service settings. In the CY 2023 PFS proposed rule, they outlined several objectives:

  • Ensuring a consistent payment approach for skin substitute products across physician offices and hospital outpatient departments.
  • Ensuring appropriate HCPCS codes describe skin substitute products.
  • Using a uniform benefit category across products within physician offices, regardless of the product’s material.
  • Maintaining clarity on CMS skin substitute policies and procedures for interested parties.

CMS plans to take a phased approach over multiple rulemaking cycles to explore incorporating skin substitutes as supplies under the PFS rate-setting methodology. Despite extensive feedback from commenters, policies have yet to be finalized.

Telehealth Services

The inclusion of caregiver training services and other wound care-related services in the Medicare Telehealth Services List is proposed. This extension will enable greater access to wound care, especially in rural or underserved areas. It supports the use of telehealth for follow-ups and continuous care management.

Health-Related Social Needs

CMS is seeking feedback on services addressing health-related social needs, including wound care. This includes exploring new ways to integrate community health initiatives with clinical care. The goal is to address social determinants that impact wound healing and overall health outcomes.

Advanced Primary Care Management Services (APCM)

The new APCM services proposed for CY 2025 emphasize coordinated care and management for chronic conditions, which can directly impact patients with chronic wounds. The focus is on comprehensive care management and reduced administrative burdens, which aim to improve patient outcomes through better care coordination.

Providers are encouraged to review the full proposal by clicking the links below. Feel free to reach out to us with questions on how these changes could impact your practice.

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Full Proposal: Federal Register Fact-Sheet: CMS

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