On November 1, the Centers for Medicare and Medicaid Services (CMS) released the CY 2025 Medicare Physician Fee Schedule Final Rule. This final ruling includes several significant changes for Rural Health Clinics (RHCs).
Key Takeaways for Rural Health Clinics
- RHC productivity standards will be eliminated for cost report periods ending after December 31, 2024.
- Starting July 1, 2025, RHCs can bill for the administration of COVID-19, pneumococcal, influenza, and Hepatitis B vaccines at the time of service. There will be an annual reconciliation established as part of the cost report process, to ensure proper reimbursement.
- The G0511 consolidated code will be unbundled, requiring RHCs to bill for care management services under a fee-for-service model. This will also allow RHCs to bill for and be reimbursed for the additional add-on codes for additional time spent providing certain services. CMS will allow a transition period as RHCs update their billing systems. The implementation date for these new billing practices will be July 1, 2025.
- New “Advanced Primary Care Management Services” billing opportunities will be established.
- Hemoglobin/Hematocrit and stool specimen examination for occult blood will be removed from the list of required RHC lab services.
- Guidance will be clarified to address discrepancies in how “primarily engaged in primary care” is defined and enforced.
- Flexibilities for same-day billing of dental services in the RHC setting will be expanded.
- Payment for IOP services will be modified to allow reimbursement for three and four-service days.
- Medicare telehealth flexibilities will be extended until December 31, 2025.
Opportunities for Rural Health Clinics
CMS will no longer measure the “primarily engaged in primary care services”. The language will be changed to reflect the requirement that RHCs still provide primary care, but it will eliminate the previous 51% threshold for Primary Care versus other services. This expands the ability for RHCs to bring in specialist services that are needed in rural communities, while also continuing to encourage and support primary care providers. For those clinics who previously did not meet the primary care threshold, the revised language may provide an opportunity to reconsider RHC designation.
CMS will remove productivity requirements for RHCs. For clinics who previously did not meet established productivity standards, the removal of these productivity standards removes any previous financial consequences through cost report adjustments. This does not diminish the importance of productivity for providers, but does not tie that productivity to a penalty for the RHC.
Contact Blue & Co. about Rural Health Clinics Opportunities
If your organization wants to talk about how the 2025 Medicare Physician Fee Schedule Final Rule impacts your RHCs, please reach out to our RHC expert or your local Blue & Co. advisor. In addition, the NARHC is hosting a webinar on Monday, November 18, 2024 from 2:00 – 3:30 p.m. EST covering these updates. You can register for this free webinar here.
