2025 CMS Final Rule: What You Need to Know About Medicare Changes

2025 CMS Final Rule—it’s here, it’s loaded, and it’s packed with changes that are going to affect practices, providers, and patients alike. If you’ve been wondering how this will impact your specialty or practice, you’re in the right place. Grab your coffee (or tea), sit back, and let’s walk through some of the key highlights of the 2025 CMS Final Rule.

Key Takeaways:

The 2025 CMS Final Rule emphasizes expanded behavioral health access through MFTs, MHCs, and telehealth.
Reimbursement rates are decreasing, with the conversion factor dropping to $32.36.
New caregiver support programs include training reimbursements for certified professionals.
Telehealth provisions remain a priority, especially for behavioral health and underserved populations.
Practices must prepare now by adjusting budgets, renegotiating contracts, and exploring telehealth.

Improving Access to Behavioral Health Services in the 2025 CMS Final Rule

One of the most exciting updates in the 2025 CMS Final Rule is a clear focus on improving access to Behavioral Health Services. This is a massive deal, especially for those working in or utilizing mental health care. Let me break it down for you:

Medicare Advantage plans—the premium-level Medicare coverage—are expanding benefits to include services from marriage and family therapists (MFTs) and mental health counselors (MHCs). This is a big step forward, building on changes from 2024 when CMS first began contracting with these behavioral health specialists.

Here’s the progression:

In 2024, CMS laid the groundwork by allowing MFTs and MHCs to contract with Medicare.
Starting in 2025, Medicare Advantage plans will cover services provided by these professionals.

What does this mean for Medicare beneficiaries? Access to more comprehensive mental health services, covered under their plans, without jumping through extra hoops. For providers in the behavioral health space, this is an opportunity to serve patients better and expand the reach of their practices.

If this applies to you, I highly recommend reading the 2025 CMS Final Rule to understand the details. It could be a game-changer for your practice.

The Reimbursement Drop: Brace Yourself

The second headline item everyone’s buzzing about in the 2025 CMS Final Rule? Reimbursement rates are going down.

Yep, we’ve seen it coming over the last decade—steady reductions in Medicare reimbursement—and 2025 isn’t bucking the trend. Specifically:

The conversion factor is dropping to $32.36 for 2025.
That’s about 93 cents lower than 2024 (and if you round it, closer to $1).

Let’s be honest: this might not sound like a massive drop at first glance. But when you add up patient volumes and services over a year, it will hit your budget hard.

If you rely heavily on Medicare patients—particularly Medicare Part B—this decrease will have an impact. That said, if your commercial payer contracts are based on an older Medicare fee-for-service schedule, you might be spared. Fingers crossed!

Pro Tip: Now’s the time to reevaluate your contracts. If you’re renegotiating or just getting started with a commercial payer, base your rates on an older, higher Medicare fee schedule. It could make a big difference.

Supporting Caregivers in the 2025 CMS Final Rule

Another standout feature of the 2025 CMS Final Rule is the increased focus on caregivers—the unsung heroes who care for chronically ill patients in their homes. CMS has identified a significant gap in resources, training, and reimbursement for this group, and it’s looking to fix it.

Here’s what’s changing:

CMS will pay for caregiver training services, but only for those who are certified and properly trained.
These reimbursements are aimed at direct care services provided to chronically ill patients.

Why does this matter? It ensures that caregivers—whether in home health agencies or private care settings—are better equipped to provide high-quality care. At the same time, it offers financial support to a group of workers who often go unrecognized.

If you’re in the home health or caregiver industry, this could open up new opportunities for services and reimbursements. Again, the devil is in the details, so grab the 2025 CMS Final Rule and read up!

What to Do Next

If you’re feeling overwhelmed by the 2025 CMS Final Rule changes, don’t panic. You’ve got time to make adjustments and plan for these updates—they don’t go into effect until January 1, 2025.

Here are a few suggestions to get started:

Review the Final Rule: Whether it’s behavioral health, reimbursement rates, or caregiver support, fully understand how these changes will impact you or your practice.
Budget Adjustments: If the lower reimbursement rates are a concern, start planning now. Look for ways to mitigate the impact, such as renegotiating contracts or adjusting services.
Educate Yourself and Your Team: Make sure you and your staff know what’s coming. Understanding the 2025 CMS Final Rule is critical for staying competitive and providing top-tier care.

Behavioral Health Expansion: More Than Just Therapists

We touched on marriage and family therapists (MFTs) and mental health counselors (MHCs) being covered under Medicare Advantage plans in 2025. But the behavioral health focus doesn’t stop there. The 2025 CMS Final Rule also addresses broader behavioral health access gaps.

CMS is making moves to tackle critical issues like:

Provider Shortages:

There’s an acknowledgment that many areas—especially rural and underserved communities—lack adequate access to behavioral health professionals. Expanded coverage for MFTs and MHCs is a start, but CMS is also encouraging the integration of behavioral health services into primary care settings.
Telehealth Services:
Telehealth continues to play a massive role in improving behavioral health access, and the 2025 CMS Final Rule ensures that certain telehealth flexibilities remain in place. While some temporary COVID-19 measures are sunsetting, CMS has kept many telehealth options alive for behavioral health, ensuring patients can connect with providers from home.

For providers: If you’re offering behavioral health services, now is the time to look into telehealth options (if you haven’t already). This is a prime opportunity to reach new patients while complying with CMS guidelines.

Reimbursement Cuts: What This Means for Practices

Okay, let’s dive a little deeper into the conversion factor drop. As advised previously, the Medicare conversion factor is dropping to $32.36, down from $33.29 in 2024. While this might seem like just a dollar, let’s explore what it means practically.

Breaking Down the Impact

The conversion factor is the base rate used to calculate Medicare service payments. It’s multiplied by RVUs (relative value units) to determine reimbursement.

Here’s a quick example:

Service	RVU	2024 Payment	2025 Payment	Difference
Level 3 Office Visit	1.5	$49.94	$48.54	-$1.40
Level 4 Office Visit	2.4	$79.90	$77.66	-$2.24
EKG Interpretation	0.5	$16.65	$16.18	-$0.47

For a high-volume practice seeing Medicare patients, this adds up quickly. If you’re performing hundreds of these services a month, you could be looking at a 5-figure annual loss in revenue.

Caregiver Training Services: A Closer Look

Caregivers are often underappreciated, but the 2025 CMS Final Rule aims to change that by addressing their training and reimbursement.

Here are the key points:

Certified Training Required:
CMS will only reimburse services provided by trained and certified caregivers. This means that home health agencies and caregiving organizations must ensure their staff meets the required standards.
Reimbursable Services:
The focus is on direct care provided to chronically ill patients, emphasizing quality and accountability. Caregivers can now access Medicare reimbursement for approved services, provided they’ve completed training programs that meet CMS guidelines.
Opportunities for Agencies:
If you run a home health agency, this is a chance to differentiate yourself. Certified caregiver training programs could help you attract more workers and ensure compliance with the new CMS guidelines.

What’s Happening with Telehealth in the 2025 CMS Final Rule?

Telehealth has been one of the most transformative aspects of healthcare in recent years, and CMS isn’t backing down on its support for virtual care. While some COVID-19-era telehealth flexibilities are set to expire, the 2025 CMS Final Rule keeps several critical provisions in place, especially for behavioral health.

Key takeaways for telehealth in 2025:

Telehealth for Behavioral Health Continues:
CMS recognizes the importance of telehealth for mental health and has ensured that many telehealth services remain reimbursable for Medicare beneficiaries.
Originating Site Flexibilities:
Patients can still access telehealth from their homes for behavioral health services without first visiting a clinical site.
Audio-Only Services:
In certain cases, audio-only visits will still be covered. This is especially important for patients in rural areas with limited internet access or those lacking video call technology.

For providers: If telehealth isn’t part of your practice, now is the time to get onboard. With telehealth services remaining a priority for CMS, expanding your practice to include virtual care could help you reach more patients and increase your revenue streams.

Quality Programs and Value-Based Care

CMS continues to push toward value-based care, and the 2025 CMS Final Rule includes updates to several quality programs to improve patient outcomes while reducing costs.

MIPS (Merit-Based Incentive Payment System):
The MIPS program has been updated with new reporting requirements and performance thresholds. If you participate in MIPS, ensure you understand the new benchmarks for 2025 to avoid penalties and maximize your reimbursement potential.
ACO Programs:
Accountable Care Organizations (ACOs) are a big focus in the 2025 CMS Final Rule, emphasizing strengthening their role in improving patient care. CMS is introducing policies to help smaller and rural providers participate in ACOs, which could lead to better coordination and higher quality care.

FAQ

What is the 2025 CMS Final Rule?

The 2025 CMS Final Rule is a set of updated regulations from the Centers for Medicare & Medicaid Services (CMS) that impact practices, providers, and patients. It includes changes to reimbursement rates, expanded behavioral health access, caregiver training programs, and telehealth provisions, effective January 1, 2025.

How does the 2025 CMS Final Rule improve behavioral health access?

The rule allows marriage and family therapists (MFTs) and mental health counselors (MHCs) to provide services covered by Medicare Advantage plans. It also supports integrating behavioral health into primary care and expands telehealth options, increasing access for underserved populations.

Why are Medicare reimbursement rates decreasing in 2025?

The conversion factor, used to calculate Medicare reimbursements, is dropping to $32.36, about 93 cents less than in 2024. Though it seems small, this reduction significantly impacts practices reliant on Medicare patients, especially for high-volume services.

How does the 2025 CMS Final Rule support caregivers?

The rule introduces reimbursement for caregiver training, ensuring caregivers are properly certified and equipped to provide quality care to chronically ill patients. This creates new opportunities for home health agencies while recognizing the vital role caregivers play.

What telehealth provisions are included in the 2025 CMS Final Rule?

The rule continues to prioritize telehealth, particularly for behavioral health. Key highlights include maintaining home as an originating site, coverage for audio-only services, and keeping telehealth flexibilities to improve patient access in rural and underserved areas.

What are the impacts of the conversion factor reduction?

The conversion factor drop affects reimbursement rates for services. For example, a Level 3 office visit will decrease from $49.94 to $48.54 in 2025. Over time, practices could face a significant financial loss, particularly those with high Medicare patient volumes.

How can practices prepare for the 2025 CMS Final Rule?

Start by reviewing the changes, including reimbursement adjustments, caregiver training opportunities, and telehealth expansions. Adjust budgets, renegotiate contracts, and educate staff to ensure compliance and financial stability in response to these updates.

What updates are there to quality programs under the 2025 CMS Final Rule?

The rule enhances programs like MIPS with new performance thresholds and reporting requirements, while ACO policies focus on improving access for smaller providers. These changes emphasize value-based care and better patient outcomes.

How does the 2025 CMS Final Rule address provider shortages in behavioral health?

CMS aims to reduce provider shortages by expanding Medicare Advantage coverage to include MFTs and MHCs, encouraging the integration of behavioral health into primary care, and maintaining telehealth flexibilities, especially for underserved areas.

What are the key takeaways from the 2025 CMS Final Rule?

The rule balances improvements, like expanded access to behavioral health and caregiver support, with challenges like reduced reimbursement rates. Practices must prepare for these shifts by adjusting budgets, exploring telehealth, and ensuring compliance with new standards.

Final Thoughts on the 2025 CMS Final Rule

The 2025 CMS Final Rule is a mix of wins and challenges. Expanded access to behavioral health services and caregiver support are definite positives, but the reimbursement cuts will leave many practices feeling the pinch.

If you haven’t already, it’s time to start planning for these changes. Whether it’s adjusting your budget, expanding into telehealth, or ensuring compliance with new caregiver training requirements, preparation will be key to navigating the road ahead.