On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released its calendar year (CY) 2024 Medicare Physician Fee Schedule Proposed Rule. With it comes numerous changes that could have significant revenue cycle management implications for your medical practice beginning January 1, 2024. We’ll dive into seven of the most important proposals worthy of your time and attention.
- Medicare payment cuts.
The proposed rule promotes a nearly 3.4% cut to what’s known as the Medicare conversion factor, a national dollar multiplier that affects the Medicare allowable amount for each procedure and service. Historically, the conversion factor has gone up and down over time to ensure budget neutrality; however, industry experts and associations raise concerns about the cut during times of increased inflation.
Act now: Do the math. Understand what proposed Medicare payment cuts might mean for your medical practice and determine whether you can leverage payment increases for new types of direct patient care to offset any losses.
- Caregiver training services.
CMS proposes to pay physicians when they train caregivers to support patients with certain diseases or illnesses, including those with dementia, autism spectrum disorders, other intellectual or cognitive disabilities, physical mobility limitations, and other conditions.
Act now: Review new code descriptions and documentation/time requirements for codes 96202 and 96203 (training for caregivers of patients with a mental or physical health diagnosis) as well as codes 9X015, 9X016, and 9X017 (caregiver training to facilitate the patient’s functional performance in the home or community). Start thinking about how to operationalize these services and capture necessary documentation.
- Community Health Integration (CHI) and Principal Illness Navigation (PIN).
CMS proposes to pay separately for services involving community health workers, care navigators, and peer support specialists. CHI is meant to address unmet social determinants of health (SDOH) needs while PIN is designed to help people with Medicare who are diagnosed with high-risk conditions such as cancer, chronic obstructive pulmonary disease, congestive heart failure, dementia, HIV/AIDS, severe mental illness, and substance use disorder. The agency seeks input on whether it should require patient consent to receive these services with the goal of avoiding surprise medical bills.
Act now: Review new code descriptions and documentation/time requirements for codes GXXX1 and GXXX2 (CHI) as well as codes GXXX3 and GXXX4 (PIN). Begin internal conversations about how to hire and leverage additional staff necessary to provide these services.
- SDOH risk assessments.
CMS proposes to add an SDOH risk assessment to the annual wellness visit (AWV) and permit separate coding and payment when physicians perform the risk assessment on the same day as an evaluation and management (E/M) service.
Act now: Review code GXXX5 (administration of a standardized, evidence based SDOH risk assessment) along with documentation/time requirements. Identify ways to perform and capture this assessment during the AWV or in conjunction with other E/M services.
- E/M visit complexity add-on.
CMS proposes an additional separate add-on payment that would apply to outpatient E/M office visits when patients have a serious or complex chronic condition.
Act now: Understand when it is—and isn’t—appropriate to report code G2211 (office/outpatient E/M visit complexity). This will undoubtedly be an area of focus for payers if CMS ultimately finalizes this code.
- Split/shared E/M visits.
CMS proposes to maintain its current definition of ‘substantive portion’ of a split or shared visit. This means providers may continue to use one of the three key components (history, exam, or medical decision making) or time (i.e., more than half the visit) to determine whether the physician or non-physician practitioner should bill for the visit.
Act now: Review your coding and documentation of split/shared E/M visits to ensure compliance.
- Telehealth services.
CMS proposes to add SDOH risk assessments to its permanent list of telehealth services. It proposes to add health and well-being coaching (codes 0591T, 0592T, and 0593T) to this list on a temporary basis.
Act now: Determine whether and how your medical practice can leverage telehealth to perform either or both services.
Looking ahead
The CY 2024 Physician Fee Schedule Proposed Rule includes many other changes—particularly for mental and behavioral health providers—that we could not cover in this brief article, including draft policy changes for the Quality Payment Program. Be sure to review these changes in their entirety and discuss potential implications for your healthcare organization.
Lisa A. Eramo, MA is a freelance healthcare writer who specializes in healthcare reimbursement, health information management, value-based care, and patient engagement. She contributes bylined articles to various healthcare trade publications and also assists clients with healthcare content marketing. You can reach her at lisa@lisaeramo.com or by visiting www.lisaeramo.com.