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Highlights of the 2024 Medicare Physician Fee Schedule proposed rule


The suggested Medicare Physician Fee Schedule for calendar year (CY) 2024 was announced by the Centers for Medicare & Medicaid Services (CMS) in July 2023. Physicians who specialize in pulmonary, critical care, and sleep medicine will be impacted by a number of policy and payment changes. Additionally, keep in mind that this is the proposed rule. Following are some of the key points for our readers:

1. The conversion factor that CMS is suggesting for 2024 is $32.75, which represents a $1.14 (–3.34%) reduction. The current conversion factor is $33.89. This is specifically meant to lower total Medicare spending.

2. It is forecast that pulmonary specialists will experience an estimated 1.09% reduction in Medicare reimbursements if the proposed changes are approved. Medicare reimbursements for critical care specialists will be reduced by 2.51%, and sleep medicine specialists will be seeing a 0.75% increase.

3. Interestingly, CMS is proposing a Healthcare Common Procedure Coding System (HCPCS) code G2211 that will have a distinct add-on payment starting on January 1, 2024. With the help of this add-on code, the resource costs of evaluation and management visits for primary care and long-term treatment of difficult patients will be more accurately recognized. In general, it will be used as an additional payment for outpatient office visits in recognition of the potential expenditures that doctors may face when treating a patient’s single, significant, or complex chronic condition over time. Payment for this add-on code would have a redistributive impact on all other CY 2024 payments, which are still lower than what was previously predicted for this policy in CY 2021 under the Medicare Physician Fee Schedule, which was not implemented at the request of various surgical specialties.

4. As you all are aware, split (or shared) E/M visits in hospitals and other institutional settings are those that are provided in part by doctors and in part by other practitioners of the same specialty but billed under a single provider. Thankfully CMS is recommending delaying the application of the “substantive portion” definition of more than 50% of the total period to at least December 31, 2024. Instead, they are going to keep the present definition of the “substantive portion” for CY 2024, which permits use of either more than half of the visit’s total time or one of the three major components (history, exam, or MDM) to determine who bills the visit. Please remember that Critical Care services (99291/99292) may also be shared or split; however, in this case, billing is based only on time.

5. According to CMS’s current regulatory stance, teaching physicians have to be physically present to charge for services involving residents at the end of the COVID-19 Public Health Emergency. Congress, on the other hand, stepped in and passed legislation to expand Medicare coverage of a number of telehealth services. In accordance with the expanded telehealth policies adopted by Congress, CMS is recommending that teaching physicians be permitted to employ audio/video real-time communications technology when the resident physician provides telehealth services to Medicare beneficiaries for CY 2024.

The CMS’s document is fairly comprehensive, so please visit this link for more information

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