Policy Snapshot
July 14, 2023
On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released its calendar year (CY) 2024 Medicare Physician Fee Schedule (PFS) Proposed Rule. As the Society analyzes the proposed rule, we wanted to inform you of a few key points.
- The proposed CY 2024 PFS conversion factor is $32.7476, a decrease of $1.14 (or 3.34%) from the current CY 2023 conversion factor of $33.8872.
Estimated Nursing Home Code Values for CY 2024
| Code | Total 2024 | 2024 Payment Rate | Total 2023 | 2023 Payment Rate | Percentage Change |
|---|---|---|---|---|---|
| 99304 | 2.39 | $78.27 | 2.38 | $80.64 | -2.94% |
| 99305 | 3.97 | $130.01 | 3.94 | $133.50 | -2.61% |
| 99306 | 5.42 | $177.49 | 5.38 | $182.29 | -2.63% |
| 99307 | 1.2 | $39.30 | 1.17 | $39.64 | -0.87% |
| 99308 | 2.22 | $72.70 | 2.2 | $74.54 | -2.47% |
| 99309 | 3.21 | $105.12 | 3.15 | $106.73 | -2% |
| 99310 | 4.58 | $149.98 | 4.53 | $153.49 | -2.28% |
| 99315 | 2.43 | $79.58 | 2.41 | $81.66 | -2.55% |
| 99316 | 3.9 | $127.72 | 3.88 | $131.46 | -2.85% |
| G0317 | 0.9 | $29.47 | 0.9 | $30.49 | -3.35% |
(Note that these are subject to change with revisions to the rule and in final rulemaking.)
- CMS proposes to remove the telehealth frequency limitations to Subsequent Nursing Facility Visit CPT Codes 99307-99310 through the end of 2024.
- For Split (or Shared) Evaluation and Management (E/M) visits for CY 2024, CMS is proposing to delay the implementation of the definition of the “substantive portion” as more than half of the total time through at least December 31, 2024. Instead, it is proposing to maintain the current definition of substantive portion for CY 2024 that allows for the 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.
- CMS is introducing five new MVPs for the 2024 performance year, and revisions to the MVPs already finalized, including adding and/or removing measures and improvement activities based on MVP inclusion criteria and information received through the MVP maintenance process.
- Using the mean final scores from 2017-2019 MIPS performance periods/2019-2021 MIPS payment years to set the MIPS performance thresholds, averaging the mean final score from each of the three performance periods (this would increase the performance threshold to 82 points for the 2024 MIPS performance year).
- Establishing the Medicare Clinical Quality Measures (CQMs) for Accountable Care Organizations (ACOs) participating in the Shared Savings Program (Medicare CQMs) as a new collection type for Shared Savings Program ACOs under the APP.
- Requiring all MIPS-eligible clinicians, Qualifying APM participants (QPs), and Partial QPs participating in a Shared Savings Program ACO (regardless of track) to report the measures and requirements under the MIPS Promoting Interoperability performance category at the individual, group, virtual group, or APM Entity level.
- Removing the numerical 75% threshold for certified EHR technology (CEHRT) for Advanced APMs and instead simply having the Advanced APM requires the use of CEHRT for QP performance periods starting in 2024.
The Society will be working on analyzing more information from the proposed rule and will make it available to members soon.