ASNC Analyzing Medicare’s 2025 Final Rules: Takeaways and Next Steps

On Friday, Nov. 1, the Centers for Medicare & Medicaid Services (CMS) posted the final rules for the 2025 Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS). ASNC’s advocacy team summarized takeaways from a preliminary analysis of both rules in an alert to members.

ASNC is now looking deeper into each rule. In the coming days, we will provide updates as well as payment charts compiling the 2025 fees for nuclear cardiology services. Watch for communications outlining how ASNC is responding to the rules, including the 2.83 percent reduction to the 2025 Medicare conversion factor in the MPFS. A priority will be collaborating with the House of Medicine to stop the physician pay cut resulting from this change to the conversion factor. You can help by using the email template in ASNC’s Action Center to contact your elected members of Congress. Tell them to stop the physician pay cut!

New Policy Separates Payment for High-Cost Radiopharmaceuticals from Medical Service Fees

As reported previously, CMS has been considering unbundling reimbursement for high-cost radiopharmaceuticals from payments for the services in which they are used. ASNC has evaluated the agency’s proposals at various junctures and provided feedback on the impact that different per-day thresholds would have on nuclear cardiology.

The 2025 HOPPS final rule finalizes separate payment for certain radiopharmaceuticals. The final policy mirrors the version in the proposed rule. View ASNC’s comments on the proposed policy here.

Starting in 2025, CMS will make separate payments for radiopharmaceuticals with a per-day cost of over $630. The new policy affects 26 radiopharmaceuticals; however, due to the $630 threshold, payments for Rb-82, N-13, and many other cardiac agents will remain bundled into procedure reimbursement.

CMS agreed with ASNC’s view that setting the per-day cost threshold at $630 will concentrate the effects of unbundling on only the products most likely to create access issues for beneficiaries while limiting the effects on the nuclear medicine ambulatory payment classifications (APCs). CMS is cognizant that a lower payment threshold would have exacerbated cuts to the nuclear medicine APCs. CMS also agreed to monitor for unforeseen effects of the unbundling and to propose modifications in future rulemaking if needed.

CMS also finalized a proposal to pay for qualifying radiopharmaceuticals using mean unit costs. The HOPPS final rule explains that CMS has insufficient average sales price (ASP) data for payment setting. (Manufacturers are not required to submit ASP data.) CMS says mean unit cost is an appropriate proxy for average price since it is calculated using average costs from hospital reports to CMS.

Stay tuned to ASNC for further analysis of the MPFS and HOPPS final rules.