In navigating the complex landscape of healthcare regulations, staying abreast of pivotal updates is paramount. The Centers for Medicare & Medicaid Services released its Medicare Physician Fee Schedule rule 2024.
According to AHA,” The Centers for Medicare & Medicaid Services Nov. 2 released its calendar year 2024 final rule for the Medicare physician fee schedule. The rule will cut the conversion factor by 3.4%, to $32.74 in CY 2024, as compared to $33.89 in CY 2023. This reflects the expiration of the 2.5% statutory payment increase for CY 2023; a 1.25% statutory payment increase for 2024; a 0.00% conversion factor update under the Medicare Access and Children’s Health Insurance Program Re-authorization Act; and a budget-neutrality adjustment.“
For healthcare providers seeking a distilled yet comprehensive overview of the 2024 PFS Final Rule, this article serves as an indispensable resource.
Responding to the AHA’s call, CMS has postponed the requirement for practitioners delivering telehealth services from home to disclose their home address on enrollment and claims forms. Originally slated for enforcement on Jan. 1, this provision will now take effect on Jan. 1, 2025. CMS invites comments on this matter for consideration in future rulemaking.
In tandem, CMS has refined the definition of the substantive portion of a split (or shared) visit. Effective for CY 2024, the “substantive portion” for Medicare billing is defined as more than half of the total time spent by the physician and non-physician practitioner during the split visit or a substantive part of the medical decision-making.
Expanding access to behavioral health services, CMS is enacting regulations directed by the Consolidated Appropriations Act of 2023. This includes creating a new benefit category for marriage and family therapists and mental health counselors under Part B, enabling them to offer telehealth services and behavioral health integration services. Furthermore, CMS has introduced new payment codes for mobile psychotherapy crisis services, as mandated by the CAA. Additionally, the agency will apply an adjustment to payments for psychotherapy services billed with a new increased complexity code and raise the payment rate for the substance use disorder bundle.
Key Elements of the 2024 Physician Fee Schedule Final Rule
- Payment: Decreases payment rates by 3.37%.
- Evaluation & Management: Defines “substantive portion” for split visits and implements add-on code G2211.
- Telehealth: Extends pandemic-era policies through Dec. 31, 2024.
- Caregiver Training: Updates services for caregivers.
- Direct Supervision: Relaxes requirements for certain providers and services.
- Social Determinants: Creates code G0136 for risk assessment.
- Appropriate Use Criteria: Rescinds program regulations.
- MIPS: Maintains 75-point threshold & adds five Value Pathways.
- Discarded Drugs: Implements policies for manufacturer refunds.
- Dental Services: Codifies previously finalized covered services.
In the realm of the Quality Payment Program (QPP), CMS has introduced five additional Merit-based Incentive Payment System Value Pathways for voluntary reporting from 2024 onward. Alongside this, CMS has approved an elevation in the performance threshold score required for MIPS participants to secure positive payment adjustments. Notably, the initially proposed augmentation of the quality data completeness threshold has been omitted. Furthermore, within the QPP’s Advanced Alternative Payment Model track, CMS is set to extend Advanced APM Incentive Payments in CY 2025 for qualifying clinicians. This extension, mandated by the CAA, ensures a one-year continuation of Advanced APM bonus payments, albeit at a reduced rate of 3.5%.
The final rule reduces the conversion factor, introduces new E/M coding changes, and extends pandemic-era telehealth policies. Additionally, it updates caregiver training, relaxes direct supervision requirements, and adds new codes and policies for social determinants of health, MIPS, drug refunds, and dental services.