United States of Care Statement: Final 2025 Medicare Physician Fee Schedule & Outpatient Prospective Payment System Rules Incorporate USofCare Priorities and Promotes Health Equity

On Friday, November 1, the Centers for Medicare & Medicaid Services (CMS) finalized the 2025 Medicare Physician Fee Schedule (PFS) and Outpatient Prospective Payment System (OPPS) rules. Taken together, both final rules will expand people’s access to affordable, equitable coverage while also moving provider payment closer toward a system grounded fully in accountable care. USofCare is grateful for the opportunity to submit comments on both rules (PFS and OPPS) during the proposed rule stage. We look forward to continuing to work with CMS to ensure that all people are able to access affordable, dependable, personalized, and understandable health care no matter their background. 

Medicare Physician Fee Schedule (PFS) final rule
The final 2025 Medicare Physician Fee Schedule (PFS) rule will increase people’s access to quality, affordable health care by expanding critical elements of patient-first care throughout the Medicare program. The final rule invests in providers across the care team, from physicians delivering advanced primary care management services to caregivers providing critical home care services, to ensure that all people, and especially those in underserved communities, have access to high-quality accountable care. 

Any shift toward patient-first care must be grounded upon a solid foundation of primary care. We are pleased to see this year’s final rule incorporate this and other lessons learned from other primary care-focused models that increase health outcomes and lower health care costs for people and the health care system generally. As mentioned in our comments, we encourage CMS to look beyond fee-for-service and consider hybrid payment models to facilitate greater access to primary care and accountable care more broadly.

Outpatient Prospective Payment System (OPPS) final rule
Several provisions USofCare supported at the proposed rule stage to protect and expand access to coverage – such as 12-month continuous Medicaid & CHIP for children, allowing people to access services from Indian Health Service facilities in new care settings, and expanding access to care for justice-involved populations – were included in the final OPPS rule. We are pleased that the final rule establishes baseline health and safety mandates for maternal care through conditions of participation (CoP) – requirements that all programs participating in Medicare and Medicaid must satisfy – for facilities offering obstetric services. 

Moving forward, USofCare encourages CMS to consider how it can lower people’s health care costs further by expanding upon existing efforts to establish site-neutral payment policy where possible in future editions of the OPPS rule and future policymaking efforts.