Nine days after the election, the practice managers we talk to are asking a version of the same question: what changes for us? The honest answer is that very little is decided yet, and the deadlines that matter most to a medical practice were set long before November 5. A new administration takes office on January 20, 2025. The current Congress still has to fund the government past December 20, and that funding bill is where most of the items below will be settled or postponed.
We are not a policy shop. What follows is an operational watchlist: five items, what is known, what is not, and what a practice can do about each in the next six weeks. We have tried to keep opinions to the parts where we actually do the work, and to keep the list to things that touch a practice's schedule, fee schedule or eligibility desk before the end of the first quarter.
Key takeaways
- The two items with January 1 consequences, the telehealth expiration and the 2.83% conversion factor cut, will be decided by the current Congress in the December funding bill, not by the incoming administration.
- Medicare Advantage plan exits and benefit changes make January 2025 eligibility churn larger than usual; re-verify every Medicare-age patient in late December and again on the day of the visit.
- ACA enhanced subsidies run through 2025 and are a 2026 budget question, not a January one.
- A HIPAA Security Rule proposal is on the HHS agenda; the controls it will ask for are ones a practice should already have.
1. Medicare telehealth flexibilities expire December 31
What is known. The statutory flexibilities that allow Medicare beneficiaries to receive telehealth at home, without a rural geographic restriction, from an expanded set of practitioners, with audio-only permitted and with the in-person requirement for mental health delayed, expire on December 31, 2024. The CY2025 Physician Fee Schedule final rule published on November 1 extended the pieces CMS controls, such as virtual direct supervision and the practitioner home address policy, but CMS has said clearly that the originating site and geographic rules require Congress.
What is not. Whether Congress attaches an extension to the December funding bill, and for how long. Extensions of one to two years have circulated in committee drafts this year, and a permanent fix has been introduced more than once without moving. Nothing is passed.
What to do. Identify every Medicare patient with a telehealth visit scheduled after January 1 and know how you would convert or reschedule it. Do not cancel anything yet. Watch the week of December 16, and know that Medicare Advantage plans can cover telehealth as a supplemental benefit regardless of what Congress does, so check each MA plan's policy separately.
2. The 2.83% conversion factor cut
What is known. The 2025 conversion factor is $32.35, down from $33.29. It takes effect January 1 unless Congress acts. Physician groups are asking for relief in the same December package.
What is not. Whether relief comes, and whether it is a full offset or a partial one as in 2024, when Congress replaced part of a 3.37% cut in March, retroactive to March 9 rather than January 1. That pattern produced two Medicare fee schedules in one year and a wave of reprocessed claims.
What to do. Budget for the full cut. Reprice Medicare Advantage contracts that are expressed as a percentage of current Medicare. If relief arrives, it arrives as upside, and if it arrives late with a mid-year effective date, as it did this year, you will have two fee schedules in 2025 and your system needs effective-dated lines to handle that. A practice collecting $1 million from Medicare Part B is looking at about $28,000 a year at constant volume.
3. ACA enhanced subsidies run through 2025
What is known. The enhanced premium tax credits for Marketplace plans, first passed in 2021 and extended in 2022, run through the end of 2025. They are not an issue for January. Open enrollment for 2025 Marketplace coverage began November 1 and runs to January 15 in most states.
What is not. Whether the next Congress extends them past 2025. Analysts on all sides expect coverage losses if they expire, which for a practice means more self-pay and more coverage changes in 2026, not 2025.
What to do. Nothing this year beyond the usual January eligibility discipline, and one small thing: make sure the front desk knows that a Marketplace patient whose plan changed for 2025 may have a new member ID and a new deductible even if the carrier name is the same. Mark the subsidy question for the 2025 budget conversation.
4. Medicare Advantage disruption during open enrollment
What is known. Open enrollment runs from October 15 to December 7, and this year's changes are larger than usual. CMS reported on September 27 that the average beneficiary can choose from 34 Medicare Advantage plans with drug coverage in 2025, down from 36, with an average premium of about $17 a month. Several carriers pulled back. Humana said its plan exits would affect roughly 560,000 members, about a tenth of its individual MA membership, and that in 13 counties it would offer no plan at all. Centene's WellCare is leaving the Medicare Advantage market in six states (Alabama, Massachusetts, New Hampshire, New Mexico, Rhode Island and Vermont). Analysts estimate that well over a million enrollees are in plans that will not exist in 2025 and must pick a new one or default to traditional Medicare.
What is not. Where your patients end up. Many will land in a plan your practice does not participate in, or will drop MA and return to Original Medicare with or without a Part D plan, and a patient who was auto-assigned rarely knows which happened.
What to do. This one has a clear operational answer. Re-verify eligibility for every Medicare-age patient on the January schedule in the last week of December and again the morning of the visit. Ask the scripted question at check-in: "Did your Medicare coverage change for January?" Train the front desk to recognize the MA plans your practice is in network with, and have the credentialing team confirm participation status for any plan new to your county. January MA eligibility denials (CO-31 and its cousins) are the most predictable denial of the year, and the most avoidable.
5. Cybersecurity rulemaking after Change Healthcare
What is known. Change Healthcare confirmed to OCR in October that about 100 million breach notices had been sent, the largest healthcare breach on record. HHS has placed an update to the HIPAA Security Rule on its regulatory agenda and has said it intends to propose stronger cybersecurity requirements for covered entities and business associates.
What is not. Whether the proposed rule appears before the administration changes, and what it requires. Proposed rules can take a year or more to become final and are often revised, and a new administration can pause pending rules.
What to do. The controls most discussed, multi-factor authentication and encryption, are ones a practice should already have. If the security risk analysis is more than a year old, update it before the end of the year regardless of what HHS proposes.
A calendar for the next six weeks
| Date | Event | Practice action |
|---|---|---|
| December 7 | Medicare open enrollment ends | Begin January eligibility re-verification |
| Week of December 16 | Government funding deadline December 20; extenders likely attached | Watch for telehealth and conversion factor language |
| December 31 | Telehealth flexibilities expire absent action; 2024 fee schedule ends | Convert or confirm January telehealth visits |
| January 1 | New fee schedule, new CPT and HCPCS codes, new deductibles | Effective-dated fee schedule live; deductible collection scripts in place |
| January 15 | Marketplace open enrollment ends in most states | Expect new member IDs on Marketplace patients through February |
| January 20 | New administration | No practice action; watch for regulatory freezes on pending rules |
What we think
Elections change the direction of policy over years. The things that hit a practice's bank account in January are set by the current Congress in the next five weeks, and by the payer contracts the practice already signed. Spend December on eligibility, fee schedules and the telehealth contingency plan, and leave the speculation to people who are paid for it. If we are wrong and Congress does something large in December, the eligibility work and the fee schedule work still needed doing.
Questions we hear
Should we stop scheduling Medicare telehealth visits in January?
No. Schedule them and keep a list. If Congress extends the flexibilities in December, nothing changes. If it doesn't, you convert the list to in-person or reschedule, and you will have had two weeks to do it. Mental health telehealth has its own rules and may continue for established patients under the in-person requirement, so keep those visits separate on the list.
Our MA patients keep asking which plan to pick. Can the front desk help?
The front desk can tell patients which plans the practice participates in and refer them to the State Health Insurance Assistance Program or Medicare's plan finder. Staff should not recommend a plan. Confirm your participation list with the credentialing team before you print it.
Where does this leave the 2025 budget?
Assume the cut, assume January eligibility churn, and assume telehealth uncertainty through the first quarter. A practice that budgets on those three assumptions and gets relief on any of them is in a better position than one that budgets on hope. Revelrex billing clients receive the January fee schedule and eligibility work as part of the service.
What to do this month
- Build the list of Medicare patients with telehealth visits scheduled after January 1, tagged in the scheduling system, and decide who owns the conversion if it is needed.
- Load the 2025 Medicare fee schedule with a January 1 effective date and confirm the system supports a second effective-dated schedule mid-year.
- Reprice every Medicare Advantage contract expressed as a percentage of current Medicare and show the owners the annual number.
- Print the list of MA plans the practice participates in for 2025, confirmed by credentialing, and put it at the front desk.
- Schedule the late-December eligibility re-verification for every Medicare-age patient on the January calendar.
- Update the security risk analysis if it is older than a year, and confirm MFA is on for email, EHR and remote access.
