CMS Finalizes 2025 Medicare Physician Fee Schedule

November 7, 2024

On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the Notice of Final Rulemaking for the 2025 Medicare Physician Fee Schedule (MPFS). Here are the key provisions affecting ABA services:

Proposed Carrier Pricing of ABA CPT Codes

CMS extended carrier pricing of the CPT codes for adaptive behavior/ABA services through 2025. That means that providers will need to continue negotiating reimbursement rates with payers.

Approval of ABA CPT Codes for Telehealth Extended through 2025

In the proposed rule, CMS maintained that they could not add any therapy billing codes to the permanent Medicare telehealth list because the agency does not have the authority to expand the list of eligible Medicare telehealth practitioners to include therapists after 2024 based on regulation 87 FR 69449 – 69451 of the federal Consolidation Appropriations Act (CAA) of 2023. The CAA extended current (COVID-era) telehealth flexibilities through the end of 2024, so CMS had proposed to let the provisional telehealth designations for all therapy codes expire on December 31, 2024. That included adaptive behavior/ABA services CPT codes 97151-97158, 0362T, and 0373T.  In the final rule, CMS has extended the provisional telehealth status of all therapy codes through 2025 and indicated that the agency plans to conduct a full review of all provisionally approved codes. For the complete list of the telehealth designations of all billing codes, go to CY 2025 PFS Final Rule List of Telehealth Services. Be sure to check your payers’ policies regarding telehealth coverage of the CPT codes for adaptive behavior/ABA services.