2025 Medicare Physician Fee Schedule (MPFS) Proposed Rule released by The Centers for Medicare and Medicaid Services (CMS) 

Extreme gratitude to our advocates at the National Association of Rural Health Clinic (NARHC) for their analyzation of the proposed rule specific to RHC’s and the related provisions to ensure that safety net providers can take full advantage of these requirements.  A brief list is provided below while NARHC works to supply a full summary in the coming weeks while submitting comments on behalf of the RHC community. NARHC DC staff will be hosting an August webinar on all these provisions to ensure that the RHC community is able to fully understand the proposed rules and provide any feedback to guide formal comments to CMS around the:

• Proposal to eliminate productivity standards
• Proposal to remove Hemoglobin / Hematocrit from the six required lab services
• Proposal for RHCs to bill HCPCS care management codes, instead of G0511
• Proposal to allow RHCs to bill for administration of part B preventive vaccines at time of service (if finalized, would begin July 1, 2025)
• Proposal to still require provision of primary care services but no longer enforce “primarily engaged in furnishing primary care services”
• Maintains that RHCs cannot be “primarily engaged in the treatment of mental diseases,” but seeks comment on how to define “mental diseases”