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The Centers for Medicare & Medicaid Services (CMS) has issued its calendar year (CY) 2024 proposed rule for the physician fee schedule (PFS). In addition to updating physician payments, the rule creates new billable services that support caregivers and the provision of whole person care. The rule also makes additional changes to the Medicare Shared Savings Program (MSSP).
Key provisions of the rule include:
Conversion Factor: The proposed CY 2024 PFS conversion factor is $32.75. This represents a decrease of 3.34% from the CY 2023 PFS conversion factor of $33.89. This reflects the expiration of a 2.5% statutory payment increase for 2023, a 1.25% statutory payment increase for 2024, and a 0% conversion factor update, and a 2.17% budget-neutrality adjustment.
Evaluation and Management Visits: CMS proposes a further delay of the implementation of its policy to define the substantive portion of a split (or shared) visit based on the amount of time spent by the billing practitioner through “at least December 31, 2024.”
Telehealth: CMS proposes to implement provisions of the Consolidated Appropriations Act (CAA) of 2023 that extended certain telehealth flexibilities through 2024. Notably, CMS proposes that, beginning in CY 2024, services furnished to people in their homes be paid at the higher non-facility PFS rate to protect access to these services, recognizing the costs of maintaining both an in-person practice setting and a robust telehealth setting.
Behavioral Health Services: CMS proposes to allow marriage and family therapists and mental health counselors, including addiction counselors, to enroll in Medicare and bill for their services. The rule also proposes increased payment for crisis care, substance use disorder treatment, and psychotherapy.
Community Health Integration Services: CMS proposes creating separate coding and payment for community health integration services. If finalized, this would include planning, health system coordination, and facilitating access to community-based resources to address unmet social needs.
Caregiver Training Services: CMS proposes paying for certain caregiver training services in specified circumstances, so that practitioners are appropriately paid for engaging with caregivers to support people with Medicare in carrying out their treatment plans.
Cancer Care Navigation: CMS is proposing payment for Principal Illness Navigation services to help patients navigate cancer treatment and treatment for other serious illnesses. These services also include care involving other peer support specialists, such as peer recovery coaches for individuals with substance use disorder.
Payment for Dental Services Prior to Cancer Treatment: The rule proposes paying for certain dental services prior to and during certain cancer treatments, including chemotherapy.
Medicare Shared Savings Program: The rule proposes additional changes to the MSSP. The most significant changes include:
- Benchmarking methodology designed to encourage accountable care organizations (ACOs) to care for complex populations
- Using assignment methodology to account for beneficiaries who receive primary care from nurse practitioners, physician assistants, and clinical nurse specialists. This proposed change is designed to attribute more underserved beneficiaries to ACOs.
The rule also includes a request for information related to risk tracks, the shared savings scaling factor, and refinements to the benchmark. A fact sheet specific to these policies is available on CMS’ website.
Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging Program: CMS formally proposes to pause implementation of its AUC program, which had previously been referenced in sub-regulatory guidance.
Clinical Laboratory Fee Schedule (CLFS) Private Payer Rate Reporting: As required by the CAA of 2023, CMS proposes to delay the CLFS private payer rate reporting period to Jan. 1-March 31, 2024; the data collection period would remain Jan. 1-June 30, 2019. CMS also proposes to make conforming changes to requirements for the phase-in of CLFS payment reductions so that payment may not be reduced by more than 15% as compared to the payment amount established for that test for the preceding year.
Quality Payment Program (QPP): CMS proposes several changes to the QPP program, including five new, optional Merit-based Incentive Payment System (MIPS) Value Pathways. CMS also proposes to increase both the performance threshold score that MIPS participants must achieve to earn positive payment adjustments, and the quality data completeness threshold. For the Advanced Alternative Payment Model track of the QPP, CMS also proposes to offer Advanced APM Incentive Payments in CY 2025 to those qualifying clinicians, as required by the CAA of 2023. A detailed fact sheet describes the QPP proposals.
The proposed rule contains numerous additional policies. A CMS fact sheet is available, and CHA will distribute a detailed summary of the rule to members in the coming weeks. Comments are due on Sept. 11.
