The Centers for Medicare and Medicaid Services (CMS) recently closed public comments on proposed rules for calendar year 2024 (CY24). The final rule is expected in November 2023, with new rules regarding the Medicare physician payment schedule taking effect after the new year.
As with any new regulation, there are a lot of details in the new Medicare Physician Fee Schedule (MPFS). There will be new billing codes and changes to how existing billing codes are used. Different medical specialties will face different impacts from the changes.
Understanding the changes to the MPFS for the coming year will be critical for doctors, medical office managers, hospital administrators, and other healthcare staff. Here's a summary of the proposed changes.
Overall Reduction in Repayment Rates
CMS has proposed an overall reduction to the MPFS conversion factor, predicting a 3.36% reduction. That means the 2024 conversion factor will be $32.75, compared to the 2023 rate of $33.89.
The reduction in rates is largely due to provisions in congressional spending laws that require budget neutrality in federal programs. Professional groups and healthcare associations offered comments to CMS and spoke with Congress about the potential effects of the rate cuts. It is not clear if there will be changes in the final rule.
Increased Reimbursements for Management of Complex Care
CMS has proposed the activation of separate add-on payments under Healthcare Common Procedure Coding System (HCPCS) code G2211. This new code, which was originally slated to take effect in 2021, provides additional payments for evaluation and management (E/M) visits for primary care and longitudinal care of complex patients. Congress froze implementation of the new code until January 2024, and CMS hopes to activate it under the final rule for the coming year.
The new code would be applicable for "outpatient office visits as an additional payment, recognizing the inherent costs clinicians may incur when longitudinally treating a patient's single, serious, or complex chronic condition." Further guidance on how the new code can be applied is expected with the publication of the final rule.
Expansion of Telehealth Reimbursements
In response to the continued use of tele-health services, including in mental health care, CMS has proposed ongoing reimbursement parity between certain tele-health appointments and office visits. Under the proposed rule, tele-health services that take place in the patient's home will be reimbursed at the same rate as an office visit. Telehealth visits that take place at locations other than the patient's home will be reimbursed at the facility visit rate.
These provisions were initially implemented as part of the public health emergency and extended through the end of 2023. The new rule would make the change permanent.
CMS proposes adding new clinical specialties to the list of approved telehealth practitioners:
- Occupational therapists
- Physical therapists
- Speech-language pathologists
- Audiologists
Expansion of Behavioral Health Services
CMS has proposed allowing qualified marriage and family therapists (MFTs), mental health counselors (MHCs), and addiction counselors to enroll as Medicare providers eligible for reimbursement under Medicare. In addition, CMS has proposed allowing clinical social workers, MFTs, and MHCs to bill for codes related to Health Behavior Assessment and Intervention (HBAI) services.
Diabetes Programs
CMS has proposed coverage of the hemoglobin A1C (HbA1c) test for diabetes and prediabetes screening, with patients eligible for two screenings within a rolling 12-month period.
CMS offers clarification on billing for the Diabetes Self Management Training program, noting that a registered dietician (RD) or nutrition professional must personally perform medical nutrition therapy services at a DSMT facility. However, an enrolled RD or nutrition professional may bill for the entire DSMT entity, regardless of which clinician personally delivers each aspect of the services.
The 2024 rule proposal also extends provisions of the Medicare Diabetes Prevention Program (MDPP) for four years.
Reimbursement for Caregiver Training
A new proposal would create a billing code for the time clinicians spend training caregivers, such as family members, on their role in implementing a treatment plan. The goal is to improve the quality of care and increase support for caregivers managing care for people with certain high-needs conditions such as dementia.
According to CMS, the code would be applicable for appointments between a caregiver and a "physician or a non-physician practitioner (nurse practitioners, clinical nurse specialists, certified nurse-midwives, physician assistants, and clinical psychologists) or therapist (physical therapist, occupational therapist, or speech-language pathologist) under an individualized treatment plan or therapy plan of care."
No Changes to Split E/M Visit Billing
CMS has proposed delaying the implementation of planned changes to how split/shared E/M visits are billed. A new policy would modify the definition of "substantive portion" to mean more than half of the total time of the visit. CMS plans to hold off on making that change until at least 2025. In 2024, the agency will maintain current split billing rules.
Add-on Code for Social Determinants of Health Screening
CMS proposed a code for performing social determinants of health (SDOH) risk assessment. The screenings would be billable when clinicians need to assess SDOH to determine factors that may impact their ability to treat the patient for serious conditions such as cancer.
In addition, clinicians may bill for SDOH screening when the screening is performed on the same day as the patient's Medicare Annual Wellness Visit (AWV). The clinician must use a culturally and linguistically appropriate, standardized, evidence-based SDOH tool to perform the screening.
Services Addressing Health-Related Social Needs
As part of Biden-Harris initiatives to expand access to patient-centered care services, CMS has proposed adding codes to account for resources used when clinicians involve in a multidisciplinary team that includes community health workers, care navigators, and peer support specialists. Specific guidance for how these new codes can be applied is expected if the program is adopted under the final rule.
The team of medical billing experts at PUREDI will integrate Medicare changes and be ready to apply them as soon as they take effect. Contact PUREDI today to learn more about how our revenue cycle management services can simplify Medicare billing for your facility or practice,
