How the 2025 Medicare Proposed Rule May Affect Urology: Billing, Coding, and Revenue Impacts
On July 10, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the proposed Medicare Physician Fee Schedule for Calendar Year (CY) 2025. This proposal details anticipated changes to payment rates and policies set to take effect on January 1, 2025. Following standard procedure, a public comment period will ensue, during which stakeholders can provide feedback. CMS will review and address these comments in the Final Rule, which is typically published in November. The Centers for Medicare & Medicaid Services (CMS) recently released the 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule, and its contents have sparked widespread analysis across medical specialties. For urologists, the proposal delivers a mix of potential financial strain, administrative complexity, and strategic opportunity. With Medicare serving as a key player for many urology practices, understanding how these changes affect urology billing, coding practices, and revenue cycle management (RCM) is vital for preparing ahead of 2025.
Medicare Conversion Factor Cut: Small Number, Big Impact
At the core of the 2025 Proposed Rule is a 1.6% decrease to the Medicare conversion factor, which is proposed to drop from $33.29 to $32.75. This adjustment may seem minor at first glance, but for high-volume specialties like urology, the cumulative financial effect could be substantial.
For context, the conversion factor is used to calculate payments for services based on the relative value units (RVUs) assigned to each CPT code. A decrease in this multiplier means that even if urologists perform the same services at the same volume, revenue will decline unless adjustments are made. CMS relies on an annual conversion factor (CF) to determine payment rates under the Medicare Physician Fee Schedule (MPFS). For 2025, the proposed CF is $32.35, marking a 2.83% reduction from the 2024 rate of $33.29. While CMS applied a modest 0.02% upward adjustment for budget neutrality, the overall decrease is primarily attributed to the expiration of the temporary 2.93% increase that Congress enacted to soften the impact of substantial cuts in 2024.
Additionally, CMS includes a regulatory impact analysis (RIA) that projects the overall payment impact on providers, beyond the CF reduction. For 2025, audiologists and speech-language pathologists (SLPs) are expected to experience no net change (0%) in payments stemming from policy updates. However, the actual financial effect on individual clinicians or practices may differ, depending on various factors such as geographic location and the mix of procedure codes billed.
Proposed Revisions to Evaluation and Management (E/M) Services – Effective January 1, 2025
For Calendar Year 2025, CMS has not proposed any significant updates to Evaluation and Management (E/M) codes. However, a notable change involves the Healthcare Common Procedure Coding System (HCPCS) complexity add-on code G2211. While G2211 is not an E/M code itself, CMS proposes expanding its use to include annual wellness visits, vaccine administration, and preventive medicine visits. No other substantial modifications to G2211 have been suggested. Urology practices are advised to continue reviewing educational materials and clinical protocols to ensure the correct application of G2211 throughout the remainder of 2024, and to be prepared for its continued use in 2025.
Delayed Implementation of Updated Medicare Economic Index (MEI) Weights
CMS has once again proposed a delay in implementing the updated MEI weights tied to the Medicare Physician Fee Schedule. Although the revised MEI data was finalized in the 2023 Final Rule, CMS intends to postpone its application to allow more time for data collection and deeper analysis regarding physician practice expense trends. This means the updated MEI figures will not yet affect reimbursement structures in 2025.
Relative Value Unit (RVU) Adjustments
Medicare estimates that RVU changes will result in a 1.0% decrease in total RVU output for urology services in 2025, assuming a similar volume of procedures as in 2024. A detailed table (referenced via a linked article) highlights codes with value shifts exceeding ±5%. Among these, the Post-Void Residual (PVR) code is the only one showing an increase, with a modest rise of just over 5%.
Several urology-related codes will see adjustments to Practice Expense (PE) valuations, following supply valuation updates by the CPT Relative Value Unit Update Committee (RUC). Key changes include:
- Endoscope cleaning/disinfecting pack (SA042): Increased from $19.43 to $31.29
- Cystoscopy drape pack (SA045): Decreased from $17.33 to $14.99
- Urology cystoscopy visit pack (SA058): Decreased significantly from $113.70 to $37.63
These supply cost changes will lead to an overall reduction in PE reimbursement for urology procedures involving cystoscopy.
Medicare Rule 2025 Urology Code Changes
| HCPCS | Modifier | Description | Percent Change | NF Total | Percent Change |
| 51798 | US urine capacity measure | 0.36 | 0.34 | 6% | |
| 51715 | Endoscopic injection/implant | 7.36 | -9.1 | -18% | |
| 51725 | TC | Simple cystometrogram | 5.82 | 7.19 | -23% |
| 51725 | Simple cystometrogram | 8.4 | 10.37 | -14% | |
| 51726 | TC | Complex cystometrogram | 5.33 | 6.58 | -23% |
| 51726 | Complex cystometrogram | 5.29 | 6.53 | -15% | |
| 51727 | TC | Cystometrogram w/up | 6.36 | 7.85 | -23% |
| 51727 | Cystometrogram w/up | “6.37 | 7.86 | -15% | |
| 51728 | TC | Cystometrogram w/vp | 4.59 | 3.72 | -23% |
| 51728 | Cystometrogram w/vp | 6.33 | 7.81 | -19% | |
| 51729 | TC | Cystometrogram w/vp&up | 3.65 | 4.5 | -23% |
| 51729 | Cystometrogram w/vp&up | 8.05 | 9.79 | -14% | |
| 51785 | TC | Anal/urinary muscle study | 9.88 | 11.99 | -23% |
| 51785 | Anal/urinary muscle study | 7.9 | 9.58 | -17% | |
| 51792 | TC | Urinary reflex study | 9.38 | 11.17 | -23% |
| 51792 | Urinary reflex study | 9.51 | 11.31 | -17% | |
| 51797 | TC | Intra-abdominal pressure test | 8.85 | 10.51 | -23% |
| 51797 | Intra-abdominal pressure test | 8.95 | 10.61 | -18% | |
| 52000 | Cystoscopy | 9.7 | 11.45 | -24% | |
| 52001 | Cysto w/removal of clots | 9.42 | 11.1 | -15% | |
| 52005 | Cysto w/ureter catheterization | 9.87 | 11.62 | 24% | |
| 52007 | Cystos w/brush biopsy ureter or renal pelvis | 4.82 | 5.67 | -16% | |
| 52010 | Cysto w/ejac duct catheterization | 11.17 | 13.12 | -18% | |
| 52204 | Cysto w/biopsy(s) | 7.02 | 8.22 | -15% | |
| 52214 | Cysto and fulguration | 10.84 | 12.58 | -10% | |
| 52224 | Cysto treat tumor minor (<0.5mm) | 11.66 | 13.47 | -9% | |
| 52265 | Cysto dilate bladder | 9.51 | 10.98 | -19% | |
| 52270 | Cysto w/internal urethrotomy female | 9.45 | 10.91 | -16% | |
| 52275 | Cysto w/internal urethrotomy male | 7.81 | 9.01 | -12% | |
| 52281 | Cysto w/dilate urethra | 11.48 | 13.15 | -22% | |
| 52283 | Cysto/steroid inject stricture | 5.98 | 6.83 | -19% | |
| 52284 | Cysto balloon cath dilate urethral stricture | 10.08 | 11.50 | -12% | |
| 52285 | Cystoscopy and treatment female urethral syndrome | 12.41 | 14.08 | -12% | |
| 52204 | Cysto w/biopsy(s) | 7.02 | 8.22 | -15% | |
| 52214 | Cysto and fulguration | 10.84 | 12.58 | -10% | |
| 52224 | Cysto treat tumor minor (<0.5mm) | 11.66 | 13.47 | -9% | |
| 52265 | Cysto dilate bladder | 9.51 | 10.98 | -19% | |
| 52270 | Cysto w/internal urethrotomy female | 9.45 | 10.91 | -16% | |
| 52275 | Cysto w/internal urethrotomy male | 7.81 | 9.01 | -12% | |
| 52281 | Cysto w/dilate urethra | 11.48 | 13.15 | -22% | |
| 52283 | Cysto/steroid inject stricture | 5.98 | 6.83 | -19% | |
| 52284 | Cysto balloon cath dilate urethral stricture | 10.08 | 11.50 | -12% | |
| 52285 | Cystoscopy and treatment female urethral syndrome | 12.41 | 14.08 | -12% | |
| 52287 | Cystoscopy chemodeveneration | 14.27 | 16.14 | -12% | |
| 52310 | Cystoscopy remove foreign body simple | 16.25 | 18.64 | -13% | |
| 52315 | Cystoscopy remove foreign body complex | 20.28 | 22.31 | -9% | |
| 52317 | Litholapaxy, small | 21.29 | 23.31 | -8% | |
| 52330 | Cystoscopy manipulation stone | 24.50 | 26.43 | -11% | |
| 52332 | Cystoscopy insert indwelling stent | 35.26 | 37.71 | -7% | |
| 52647 | Laser surgery of prostate | 44.63 | 46.75 | -5% |
Specialty Reimbursement: Urology Facing a 1% Drop
CMS estimates that urology will see a 1% average reduction in total Medicare reimbursement under the proposed rule. Although this average may vary depending on procedure mix and coding practices, the dip in payment comes at a time when many practices are already managing rising operational costs, staffing shortages, and increased documentation burdens.
This highlights the need for efficient urology billing practices and a proactive strategy to capture every legitimate dollar earned.
Coding Changes Tweaks to E/M and Split/Shared Visits
The 2025 rule continues CMS’s multi-year journey of refining Evaluation and Management (E/M) services, originally overhauled in 2021 and expanded in 2023 to include inpatient and observation care.
For urology practices, the most relevant changes include:
- Refinements to split/shared E/M visits: When both a physician and a non-physician practitioner (NPP) contribute to a single E/M service, billing can only be attributed to the clinician who performs the “substantive portion”. CMS is proposing to define this portion based solely on time spent rather than medical decision-making.
- Streamlined documentation requirements: While intended to reduce administrative burden, any change to E/M rules necessitates updates to internal workflows and staff education to ensure compliance.
These updates reinforce the importance of accurate coding and timely documentation within the revenue cycle.
The Role of RCM: From Passive Billing to Strategic Management
The 2025 Medicare Physician Fee Schedule Proposed Rule reinforces a critical evolution in healthcare operations: revenue cycle management (RCM) is no longer a passive, back-office function. Instead, it has become a strategic pillar of financial sustainability, especially in specialty practices like urology, where reimbursement dynamics are increasingly complex.
With policy updates such as shifts in RVU valuations, expansion of complexity add-on codes like G2211, and delayed implementation of Medicare Economic Index (MEI) adjustments, practices must adopt a more agile and integrated approach to revenue cycle management. In this new environment, RCM is not just about billing correctly—it’s about anticipating regulatory change, maximizing reimbursement, and avoiding costly errors.
To thrive under the 2025 framework and beyond, urology practices should take a more proactive and comprehensive RCM approach. Key strategies include:
1. Audit and Optimize Coding Accuracy
Regular internal audits should be conducted to ensure correct coding of Evaluation & Management (E/M) and procedural services, particularly those undergoing policy changes. Accurate use of CPT codes, modifiers, and documentation requirements is essential to avoid claim rejections and delays. Special attention should be paid to new or revised codes, like the broadened applicability of G2211, and high-impact procedural codes with altered RVU or practice expense valuations.
2. Educate Providers and Billing Staff
As coding rules grow more nuanced—especially for services like split/shared visits—ongoing training is essential. Providers must be well-versed in documentation standards, while billing and coding teams should understand payer-specific requirements. Cross-functional alignment between clinical and administrative staff ensures defensible claims and helps prevent compliance issues.
3. Leverage Advanced RCM Technology
Investing in technology-enabled RCM solutions can dramatically improve accuracy and efficiency. Tools that provide real-time coding suggestions, automated claims scrubbing, and payer rule updates help minimize human error and increase clean claim rates. Integration with electronic health records (EHR) and billing systems further enhances data consistency and financial transparency.
4. Monitor MIPS Performance and Quality Metrics
Performance under the Merit-based Incentive Payment System (MIPS) has a direct impact on Medicare reimbursement. Practices should regularly review MIPS dashboards and address gaps in quality reporting, improvement activities, and cost-efficiency. Avoiding negative payment adjustments requires ongoing tracking, proactive planning, and timely corrections.
Looking Ahead: Adaptation Is Key
The Medicare Proposed Rule is not yet finalized, and CMS is accepting comments until early fall. However, history suggests that most of the core proposals—including the conversion factor cut—are likely to stick in some form.
For urologists, that means now is the time to:
- Evaluate financial exposure to payment cuts.
- Implement training on new coding and documentation rules.
- Strengthen RCM operations to maximize collections and maintain cash flow.
With CMS doubling down on value-based care and cost containment, success in the coming year will hinge on clinical excellence matched by administrative precision.
Effects on Urology Billing, Coding, and Practice Revenue
As regulatory changes and payment adjustments continue to shape the healthcare landscape, urology practices are facing significant shifts in billing, coding, and overall revenue strategies. The proposed 2025 Medicare Physician Fee Schedule (MPFS) brings several key developments that urologists must prepare for—ranging from updates to code valuations to broader revenue cycle implications.
1. Billing Impacts from RVU and Conversion Factor Reductions
One of the most immediate effects is the decrease in the Medicare conversion factor (CF) for 2025, proposed to drop from $33.29 in 2024 to $32.35—a 2.83% reduction. This decline is compounded by the expiration of the temporary 2.93% increase enacted by Congress in 2024 to ease prior cuts. For urology practices that rely heavily on Medicare reimbursement, even small percentage changes can significantly affect revenue projections.
Additionally, Relative Value Unit (RVU) revisions for various urological procedures are expected to lead to a 1.0% overall decline in RVU-based reimbursement, assuming volume remains stable. For some high-volume services like cystoscopy procedures, these adjustments may alter cost-recovery ratios and affect case profitability.
2. Coding Adjustments and Complexity Add-on Code Expansion
Although Evaluation and Management (E/M) codes will remain largely unchanged for 2025, CMS proposes to expand the use of complexity add-on code G2211 to include preventive services, vaccine administration, and annual wellness visits. This shift presents both an opportunity and a challenge—accurate documentation and coder education will be critical to ensure proper use of G2211 and avoid billing errors.
Moreover, updates in practice expense (PE) valuations—such as those tied to cystoscopy supplies—will directly impact reimbursement for many standard urologic procedures. For instance, the reduction in valuation for the “pack, urology cystoscopy visit” from $113.70 to $37.63 will lower reimbursements for procedures involving this supply, despite no changes in the procedural CPT codes themselves.
3. Revenue Cycle Management
Given these shifts, urology practices must evolve their approach to revenue cycle management (RCM). No longer a passive back-office task, RCM has become a frontline strategy for maintaining practice viability. Practices need to:
- Conduct routine audits of coding and documentation to ensure compliance and accuracy.
- Invest in technology-driven RCM solutions that include real-time coding guidance and automated claims scrubbing.
- Track MIPS (Merit-based Incentive Payment System) performance to avoid unnecessary penalties and leverage incentive opportunities.
4. Adapting for Long-Term Financial Health
To mitigate revenue pressure, urology practices should take a forward-looking stance by:
- Optimizing clinical workflows to capture all billable services accurately.
- Educating providers and billing teams on evolving payer rules.
- Exploring diversified revenue streams, such as ancillary services or telehealth consultations where reimbursable.
Wrapping Up
While the 2025 Medicare Proposed Rule may bring new challenges for urologists, it also opens the door for critical improvements in billing accuracy, coding efficiency, and revenue cycle management (RCM) strategies. CureCloudMD is here to keep you informed of every important update, helping your practice stay ahead of regulatory changes. The evolving Medicare rules for 2025 underscore the need for urology practices to be proactive, data-driven, and agile in their billing and coding processes. By staying informed and partnering with experts like CureCloudMD, practices can turn regulatory challenges into opportunities for improved efficiency, compliance, and revenue growth.With timely insights and proactive support, urology practices can not only adapt to these shifts but also strengthen their financial resilience and operational workflows—ensuring long-term success in an ever-changing healthcare landscape.
