The Centers for Medicare & Medicaid Services (CMS) released its calendar year (CY) 2024 proposed rule for the physician fee schedule. The rule proposes a decrease to the conversion factor by 3.34%, to $32.75 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 CHIP Reauthorization Act; and a -2.17% budget-neutrality adjustment. Other provisions in the proposed rule include:
- Delaying implementation of a split (or shared) visit based on the amount of time spent by the billing practitioner. Under this policy, if a non-physician practitioner performed at least half of an evaluation and management visit and billed for it, Medicare would only pay 85% of the physician fee schedule rate.
- Creating a new benefit category for marriage and family therapists and mental health counselors under Part B. In addition, the CMS would establish new payment codes for mobile psychotherapy for crisis services.
- Creating five new, optional Merit-based Incentive Payment System (MIPS) Value Pathways for reporting beginning in 2024. The 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.
- Extending the Advanced Alternative Payment Model (APM) Incentive Payments into CY 2025 to those qualifying clinicians. This one-year extension of Advanced APM bonus payments at a reduced rate of 3.5% was required by the Consolidated Appropriations Act of 2023.
- Extending several telehealth waivers, such as reimbursement at the non-facility rate for certain telehealth services in the patients’ home.
The CMS will accept comments on the proposed rule through Sept. 11. Members with questions may contact Jason Jorkasky at the MHA.