Medicare 2024 Physician Fee Schedule Proposed Rule Key Points

On July 13th, the Centers for Medicare and Medicaid Services (CMS) published the 2024 Medicare Physician Fee Schedule proposed rule (PFS) which includes proposed Medicare Part B payment policies for the coming calendar year. 

CY 2024 Conversion Factor 

The proposed Calendar Year (CY) 2024 PFS Conversion Factor (CF) is $32.75, a reduction of $1.14 compared to the 2023 PFS CF of $33.89 

The proposed Anesthesia CF is $20.44, a reduction of $0.68 compared to the 2023 Anesthesia CF of $21.12. 

2024 Medicare Physician Fee Schedule

Evaluation and Management (E/M) Add-on Code 

Beginning January 1, 2024, CMS is proposing to implement a separate add-on payment to be billed using healthcare common procedure coding system (HCPCS) code G2211. This add-on code will better recognize the resource costs associated with evaluation and management visits for primary care and longitudinal care of complex patients. 

If finalized, CMS expects that establishing payment for this add-on code would have redistributive impacts for all other CY 2024 PFS payments due to statutory budget neutrality requirements and is somewhat responsible for the reduced CF. 

Split (or Shared) Services 

Split (or shared) E/M visits refer to visits provided in part by physicians and in part by other practitioners in hospitals and other institutional settings. For CY 2024, CMS proposes to delay the implementation of our definition of the “substantive portion” as more than half of the total time through at least December 31, 2024. Instead, CMS proposes to use the 2022 definition of substantive portion for CY 2024 that allows for use of either one of the three key components (history, exam, or MDM) or more than half of the total time spent to determine who bills the visit. 

Telehealth 

CMS is proposing to continue to permit virtual direct supervision where supervising practitioner is immediately available through real-time audio and video interactive telecommunications through December 31, 2024. 

Merit-based Incentive Payment System (MIPS) 

CMS proposes to increase the MIPS performance threshold from 75 points to 82 points. Here is the list of five new MIPS Value Pathways (MVPs) that CMS is proposing to add in 2024. 

  1. Focusing on Women’s Health 
  2. Quality Care for the Treatment of Ear, Nose, and Throat Disorders 
  3. Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV 
  4. Quality Care in Mental Health and Substance Use Disorders 
  5. Rehabilitative Support for Musculoskeletal Care.