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Policy Brief | Health-Equity-Alliance

HEA Policy Briefing: CY2025 Medicare Physician Fee Schedule (MPFS) Final Rule

On November 1, CMS unveiled the final rule for the Calendar Year (CY) 2025 Medicare Physician Fee Schedule (MPFS). The agency included a number of health equity updates, including a new health equity benchmark adjustment (HEBA) and prepaid savings option for Medicare Shared Savings Program (MSSP) ACOs as well as 3 new Advanced Primary Care Management (APCM) codes that account for increasing resource utilization in managing primary care patients based on number of chronic conditions and social risk.

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What's Inside

  • MSSP Health Equity Benchmark Adjustment (HEBA): The HEBA is intended to benefit ACOs serving a larger proportion of beneficiaries from underserved communities by providing an upward adjustment to the historical benchmark.

  • MSSP Prepaid Shared Savings: This option provides additional cash flow for ACOs that meet specific criteria, including positive prior savings adjustment, to invest in staffing (e.g., community health workers), infrastructure (e.g., audiovisual interpreter technology), and direct services to beneficiaries (e.g., nutrition support).

  • Health System Sentiment on Services Addressing Health-Related Social Needs (HRSN): Common concerns among HEA members on the limitations and unintended consequences of new HCPCS codes reimbursing for services addressing HRSN finalized last year