Summary of 2024 Physician Fee Schedule

​The Centers for Medicare and Medicaid Services (CMS) on July 13 released the 2024 Medicare Physician Fee Schedule (PFS) proposed rule, addressing Medicare payment and quality provisions for physicians in the coming year. Some of the major provisions include:

• Under the proposal, physicians will see a decrease to the conversion factor of 3.36% on Jan. 1, 2024, going from $33.8872 to $32.7476.
• CMS projects that overall reimbursement for interventional pain management services will remain flat compared to 2023, with changes to policies and individual services roughly balancing out.
• CMS proposed to maintain the work RVUS for CPT code 63685, Insertion or replacement of spinal neurostimulator pulse generator or receiver, direct or inductive coupling at 5.19 which is the current wRVU for 63685.  They also proposed a new wRVU for 63688, Revision or removal of implanted spinal neurostimulator pulse generator or receiver which currently is valued at 5.30 wRVUs but was proposed to be revalued to 4.35 work RVU for 2024.
• CMS also proposed to carrier price three new CPT codes scheduled to go into effect for 2024.  These codes are for the percutaneous insertion and removal of integrated neurostimulator systems in peripheral nerves.  Carrier pricing means individual Medicare MACs will set their own pricing and payment policies for these services for 2024.
• A proposal to pause implementation of the Appropriate Use Criteria (AUC) Program for reevaluation and to rescind the current AUC program regulations. CMS will continue efforts to identify a workable approach, which may be proposed in subsequent rulemaking.
• A proposal to further delay implementation of the split/shared billing changes, allowing history, exam, medical decision making or time to determine who bills the visit. CMS proposes to postpone implementation of prior changes through at least Dec. 31, 2024. The prior proposal would have redefined the definition of "substantive portion" to mean more than half of the total time. Clinicians who furnish split/shared visits will continue to have a choice of history, physical exam, or medical decision making, or more than half of the total practitioner time spent to define the substantive portion, instead of using only total time.
• A proposal to implement a separate add-on code and payment for enhanced visit complexity of primary care and longitudinal care of complex patients. G2211 would generally be applicable to outpatient office visits as an additional payment, recognizing the costs clinicians may incur when longitudinally treating a patient's single, serious or complex chronic condition. If finalized, establishing payment for this add-on code would have redistributive impacts for all other calendar year 2024 payments. While those effects are less than estimated for this policy when first proposed for 2021, it still drives a significant portion of the proposed conversion factor reduction.

Telehealth Provisions and Inflation Reduction Act Implementation

• A proposal to implement several telehealth-related provisions of the Consolidated Appropriations Act, 2023 that would be in effect until Dec. 31, 2024.
• Policies in place until Dec. 31, 2024 include the temporary expansion of telehealth originating sites for services furnished via telehealth to include any site in the U.S. where the beneficiary is located at the time of the telehealth service, including an individual's home; delaying the requirement for an in-person visit with the physician or practitioner within six months prior to initiating mental health telehealth services; and the continued coverage and payment of telehealth services included on the Medicare Telehealth Services List.
• A proposal to continue defining direct supervision to permit the presence and immediate availability of the supervising practitioner through real-time audio and video interactive telecommunications through Dec. 31, 2024, to avoid an abrupt transition at the end of 2023.
• A proposal to allow teaching physicians to use audio/video real-time communications technology when the resident furnishes Medicare telehealth services in all residency training locations through Dec. 31, 2024.
• Telephone E/M codes 99441-99443 and 98966-98968 will remain actively priced through 2024 under flexibilities included in the Consolidated Appropriations Act, 2023.
• A proposal to extend current Opioid Treatment Programs flexibilities for periodic assessments that are furnished via audio-only telecommunications through the end of CY 2024.
• 2024 Quality Payment Program Performance Period
• CMS is proposing several updates to the Quality Payment Program (QPP) and Medicare Shared Savings Program for 2024. Highlights include:
• An increase in the performance threshold from 75 to 82 points. This modest increase would be applicable to all three MIPS reporting options (traditional MIPS, MVPs, and the APP).
• Minor changes to the Cost, Quality, Improvement Activities and Promoting Interoperability performance categories have been proposed. For the CY 2024 performance period/2026 MIPS payment year, the scoring weights are as follows: 30% for the quality performance category; 30% for the cost performance category; 15% for the improvement activities performance category; and 25% for the Promoting Interoperability performance category.
• CMS proposes a total of 200 quality measures for the 2024 performance period by addressing changes to 59 existing MIPS quality measures, partial removal of three quality measures from the MIPS quality measure inventory, removal of 12 quality measures, and the addition of 14 
• A proposal to eliminate the health IT vendor category of third-party intermediaries, beginning with the CY 2025 performance period. Instead, CMS would require health IT vendors who wish to submit data on behalf of clinicians to meet the requirements and self-nominate as a qualified registry or qualified clinical data registry (QCDR). CMS also proposes updating qualified registry and QCDR self-nomination and approval policies for CY 2024.
• A proposal to establish the Medicare Clinical Quality Measures (CQMs) for Accountable Care Organizations (ACOs) Participating in the Medicare Shared Savings Program as a new collection type for Shared Saving Program ACOs under the Alternative Payment Model (APM) Performance Pathway (APP)

​​Additional information on the rule can be found in the Medicare PFS Press Release, Medicare PFS Fact Sheet, Medicare Shared Savings Program Fact Sheet, and QPP Fact Sheet [PDF]. ACC Advocacy staff will continue to provide more detailed information on elements of the proposed rule in the weeks ahead and develop comments for submission within the 60-day comment period. Look for updated information on ACC.org/Advocacy and in upcoming issues of The Advocate newsletter. For more on the Medicare PFS regulatory process, access ACC's Physician Fee Schedule Roadmap [PDF].