CMS Issues CY 2024 Medicare Physician Fee Schedule Proposed Rule

Additional Details

Reimbursement Updates

• CMS is proposing a CY 2024 conversion factor of $32.75, which is 3.34% less than the CY 2023 conversion factor of $33.89. Similar to the conversation factor decrease experienced in 2023, this reduction continues to reflect the expiration of the statutory payment increase and budget neutrality adjustments.

Coding and Coverage

• Caregiver Training Services: CMS is proposing to provide payment when practitioners (including physicians, nonphysicians, and therapists) train and involve caregivers to support patients with treatment plans for certain diseases and illnesses, such as dementia.
• Services for Health-Related Social Needs:To better account for resources needed to provide multidisciplinary support, CMS is proposing to pay separately for Community Health Integration (CHI), Social Determinants of Health (SDOH) Risk Assessment, and Principal Illness Navigation Services (PIN).
  • CMS is proposing to add the SDOH risk assessment to annual wellness visits as an optional element offering additional payments. The agency is also proposing codes and payments for these risk assessments to occur on the same day as an E&M visit.
• Add-On Payment for E&M Service:For CY 2024, CMS is proposing a new add-on payment for HCPCS code G2211 (prolonged office/outpatient E&M services) to account for the cost of providing longitudinal and chronic condition care services.
  • Of note, this policy was originally finalized in CY 2021, but Congress subsequently suspended the use of add-on codes until January 2024.
• Split/Shared E&M Visits: CMS is proposing a further delay in implementing the “substantive portion” definition, slated to be defined as more than half of the total visit time. This delay will continue through at least December 31, 2024. In the interim, CMS is proposing to maintain the current definition. See ECG’s summary of the proposed delay here.
• Telehealth Service Flexibility: CMS is proposing several updates to continue providing practitioners with flexibility around how telehealth can be furnished. However, several proposals are temporary and would remain only through the end of 2024. Proposals include:
  • Addition of health and well-being coaching services to the list of covered Medicare Telehealth Services on a temporary basis for CY 2024
  • Permanent addition of Social Determinants of Risk Assessments to the Medicare Telehealth Services List
  • Use of nonfacility PFS rate for telehealth services furnished to people in their homes
  • Continuation of the direct supervision definition to permit the presence of a supervising practitioner through live audio and video interactive telecommunications through December 31, 2024
  • Implementation of provisions mandated by the Consolidated Appropriations Act (CAA) of 2023, including but not limited to temporary expansion of originating telehealth sites, expansion of the definition of telehealth practitioners, and continued payment for telehealth services furnished by Rural Health Clinics and Federally Qualified Health Centers
• Behavioral Health Services:
  • To implement provisions from the 2023 CAA, CMS is proposing to allow MFTs and MHCs to enroll in Medicare after the CY 2024 PFS final rule is published. These providers would then be able to bill Medicare for services starting January 1, 2024.
  • Also included in the CAA, CMS is proposing to establish new HCPCS codes for psychotherapy crisis services that are furnished in a covered site of care. The CAA also specifies that payment for these crisis services shall be equal to 150% of the fee schedule amount for nonfacility sites of service for each year.
  • CMS is also proposing to allow Health Behavior Assessment and Intervention (HBAI) services (CPT codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168) to be billed by clinical social workers, MFTs, MHCs, and clinical psychologists.
  • Finally, CMS is proposing to apply an adjustment to the work RVUs for psychotherapy codes payable under the PFS. CMS is proposing implementation over four years to more accurately value time-based behavioral health services.
• Opioid Treatment Programs (OTPs): CMS is proposing to extend current flexibilities to allow for assessments furnished via audio-only telecommunications through the end of CY 2024.

_{Edited by: Matt Maslin}

Published July 17, 2023