The first Medicare remittances of 2025 will land in the next two weeks, and the allowed amounts will be a little lower than the ones you saw in December. That is not a posting error. The 2025 Medicare Physician Fee Schedule took effect on January 1, 2025, and the conversion factor fell from $33.2875 to $32.3465, a cut of about 94 cents or 2.83 percent. CMS published the final rule on November 1, 2024. Congress did not include a fix in the December spending bill, so the cut is live.
We have spent the last week walking practices through what actually changes in their workflow, and the honest answer is: less than the headlines suggest, but more than nothing. The rate cut needs a fee schedule update and a conversation with anyone who watches the underpayment report. Two coding changes need ten minutes with providers. One deadline at the end of March needs a plan.
Key takeaways
- Every Medicare allowed amount is 2.83 percent lower than in 2024 for the same code and locality. Load the 2025 schedule so variance reports stop flagging every line.
- G2211 is now payable alongside an office visit with modifier 25 when the visit is on the same day as an annual wellness visit, vaccine administration or another Part B preventive service.
- Three new advanced primary care management codes (G0556, G0557, G0558) can be billed monthly, but not in the same month as chronic care management for the same patient.
- Medicare will not pay the new CPT telemedicine codes 98000 to 98015. Keep billing 99202 to 99215 for Medicare telehealth; 98016 replaces G2012.
- The broad telehealth flexibilities run only through March 31, 2025. Plan for April now.
The conversion factor and what it does to your allowed amounts
Every Medicare physician payment is the code's relative value units (RVUs, the weights CMS assigns for work, practice expense and malpractice) multiplied by the conversion factor, adjusted for your locality. Because the conversion factor changed, every code changed by the same percentage. A service with 3.0 total RVUs was worth $99.86 nationally in 2024 and is worth $97.04 in 2025, before the geographic adjustment. The table below is simple arithmetic, but it is the number the practice owner will ask for.
| 2024 Medicare allowed charges | Expected 2025 allowed at the same volume and code mix | Difference |
|---|---|---|
| $250,000 | $242,925 | $7,075 less |
| $600,000 | $583,020 | $16,980 less |
| $1,200,000 | $1,166,040 | $33,960 less |
Two things to do this week. First, load the 2025 Medicare fee schedule for your locality into the practice management system so expected-payment and underpayment reports stop flagging every Medicare line as short. If your system uses the national rate times the geographic practice cost index, update both. Second, check any commercial contract that pays as a percentage of "current Medicare". Some of those contracts follow the 2025 schedule automatically and some are tied to a fixed year, for example "the 2023 Medicare Physician Fee Schedule". Read the definition before you assume, because a contract tied to a fixed year just became more valuable and a contract tied to "current" just took the same cut.
Physician groups are pressing Congress to reverse the cut in the next must-pass bill. Bills to do that were introduced in the last Congress and will be reintroduced. We think it is reasonable to hope, but do not budget for it. If a fix passes later in the year, it will most likely apply prospectively, and the January through March remittances will stand as paid.
G2211 can now be billed with modifier 25 in specific visits
The add-on code G2211 (visit complexity inherent to evaluation and management visits associated with ongoing care) has been payable since 2024, but it was not payable when the office visit carried modifier 25. That exclusion is narrower in 2025. CMS now allows payment of G2211 when the E/M visit with modifier 25 is on the same day as an annual wellness visit, an initial preventive physical examination, vaccine administration, or any Medicare Part B preventive service.
In practice, this affects primary care most. A 68-year-old patient comes in for the annual wellness visit and the provider also manages hypertension and diabetes during the same encounter. The claim carries G0439, 99214 with modifier 25, and now G2211. Before January 1 the G2211 line would have been denied. The documentation requirement has not changed: the provider must be the continuing focal point for the patient's care, and the note should make that relationship visible, for example by naming the chronic conditions being managed over time and the plan for the next visit.
The exclusion still applies when modifier 25 is used because a minor procedure was done on the same day. A 99213-25 with a joint injection does not qualify for G2211. Build the scrubber rule around the companion code, not around the modifier: if the same-day service is a preventive service or vaccine administration, allow G2211; if it is a procedure with a global period, block it.
Advanced primary care management: three new monthly codes
CMS finalized three new HCPCS codes for advanced primary care management (APCM), G0556, G0557 and G0558, billed once per calendar month by the practitioner who serves as the patient's continuing focal point for care. The three levels are tiered by patient complexity: G0556 for patients with one or no chronic conditions, G0557 for patients with two or more, and G0558 for qualified Medicare beneficiaries with two or more chronic conditions. The codes bundle elements of chronic care management, principal care management and communication technology services, and they do not carry the minute thresholds that made CCM hard to document.
We are cautious about recommending a rush into APCM. A practice cannot bill APCM and CCM for the same patient in the same month, and the service elements (24/7 access, a comprehensive care plan, transitions of care, patient consent, performance measurement) have to be real. If your practice already runs a CCM program with good enrollment, model both options with your own patient mix before switching: a patient who reliably generates 99490 plus 99439 add-on units may pay more under CCM than under G0557. If you have no care management program at all, APCM is a simpler on-ramp than CCM ever was, and the consent conversation can start at the annual wellness visit.
The new telemedicine CPT codes and why Medicare mostly ignores them
The 2025 CPT code set introduced 17 new telemedicine E/M codes, 98000 to 98016: 98000 to 98007 for audio-video visits, 98008 to 98015 for audio-only visits, and 98016 for a brief virtual check-in of five to ten minutes. Medicare assigned an invalid status to 98000 through 98015 and will not pay them. It does pay 98016, which replaces HCPCS code G2012.
So for Medicare patients you continue to bill telehealth visits with the standard office E/M codes, 99202 to 99215, with place of service 10 when the patient is at home and modifier 93 for audio-only. For commercial patients it depends on the payer. Several Blue plans and other commercial payers have said they will accept the 98000 series from January 1, 2025, and some pay them at a different rate than in-person E/M. This is the part everyone skips: build a payer-by-payer table now, because a claim scrubber that applies one rule to every payer will get half of them wrong.
| Scenario | Medicare | Commercial payer that adopted the 98000 series |
|---|---|---|
| Audio-video visit, patient at home | 99202 to 99215, POS 10 | 98000 to 98007 (or payer instruction) |
| Audio-only visit, patient at home | 99202 to 99215, POS 10, modifier 93 | 98008 to 98015 (or payer instruction) |
| Brief 5 to 10 minute check-in | 98016 | 98016 if adopted, otherwise payer instruction |
Other 2025 changes worth a line in your checklist
The Medicare Part B deductible is $257 for 2025, up from $240. Front desks will see it on the first remittances of the year, and patients will owe it on their first visits. Expect the January eligibility responses to show the full deductible remaining for nearly every Medicare patient, and collect accordingly.
Teaching physicians may continue to provide virtual presence for resident services through 2025, and the broader allowance for direct supervision through real-time audio and video is also extended through the end of the year. Distant-site practitioners may keep using their practice address rather than their home address on enrollment records. None of these need a system change, but they are the answers to questions your providers will ask.
The broad telehealth flexibilities (home as originating site, no geographic restriction, audio-only coverage, the delayed in-person requirement for tele-mental health) are extended only through March 31, 2025, by the December spending bill, the American Relief Act, 2025. Unless Congress acts again, Medicare telehealth returns to the pre-2020 rules on April 1, which would mean most patients at home could no longer be seen by telehealth for a Medicare-payable visit. We think an extension is likely but not certain, and a practice with a heavy telehealth schedule should have two April templates ready.
Questions we hear
Should we hold Medicare claims until the fee schedule is loaded?
No. Medicare pays from its own schedule regardless of what you bill. Submit as usual and update your expected-payment tables so the variance reports make sense. Holding claims only adds days to your accounts receivable, and the January remittances are the fastest way to confirm that your locality figures are right.
Do we need to re-train providers on G2211?
A ten-minute conversation is enough. The message is simple: if you are the patient's continuing physician and the visit is with a wellness visit, a vaccine or another preventive service, G2211 is now allowed with modifier 25. If the modifier is there because of a procedure, it is not. Coders should check the first two weeks of claims by hand before trusting the scrubber rule.
What about the telehealth deadline?
Plan two schedules for April: one if Congress extends the flexibilities again and one if it does not. Decide now which telehealth patients would be moved to in-person visits, and which could be seen under the permanent exceptions (behavioral health at home, for example). Our medical billing team is tracking payer responses, and if you want a review of how the 2025 changes land in your own contracts and code mix, book a call.
What to do this month
- Load the 2025 Medicare fee schedule for your locality into the practice management system and re-run the underpayment report for the first January remittances.
- Pull every commercial contract that references Medicare rates and record whether it points at "current" Medicare or a fixed year.
- Update the scrubber so G2211 is allowed with a modifier 25 visit when the companion code is a preventive service or vaccine administration, and blocked when it is a procedure.
- Decide whether to model APCM against your existing CCM program, and if so pull the CCM billing history for the last twelve months.
- Build the payer-by-payer telemedicine code table for the 98000 series and keep Medicare on 99202 to 99215.
- Update patient responsibility scripts for the $257 Part B deductible.
- Put March 31 on the calendar and draft the two April telehealth schedules.
