On Thursday, July 13, the Centers for Medicare & Medicaid Services (CMS) filed the 2024 Medicare Physician Fee Schedule (PFS) proposed rule, which includes potential revisions to payment policies under the physician fee schedule, the quality payment program and other Part B payment policies. AASM Health Policy staff will review the rule and develop comments on behalf of the AASM membership. Several key highlights of the rule include:

The proposed Medicare conversion factor for 2024 is $32.7476, a 3.36% reduction from the 2023 conversion factor.

CMS projects the Medicare Economic Index (MEI) will be 4.5%. The Agency will continue to postpone implementation of the updated MEI weights, as the AASM and many other medical specialty societies urged them to consider data collected from the American Medical Association’s updated Physician Practice Information survey, which launches July 31.

CMS is proposing to implement a separate add-on code and payment for HCPCS code G2211 to better recognize the resource costs associated with evaluation and management visits for primary care and longitudinal care for complex patients.

For 2024, CMS is proposing to delay the implementation of their definition of “substantive portion” as it relates to split or shared visits. The Agency will instead maintain the current definition for 2024, which allows use of any one of the three key components (history, exam, or medical decision making).

After ongoing advocacy from AASM and other medical specialty societies regarding telehealth policies, CMS is proposing several telehealth-related provisions from the Consolidated Appropriations Act of 2023 (CAA, 2023). Examples include:

  • Temporary expansion of the scope of telehealth originating sites for services furnished via telehealth to include any site in the U.S. where the beneficiary is located at the time of the telehealth service (including the individual’s home)
  • Expansion of the definition of telehealth practitioners

CMS is proposing that beginning in 2024, telehealth services furnished to people in their homes be paid at the non-facility PFS rate to protect access to mental health and other telehealth services by aligning with telehealth-related flexibilities that are extended via the CAA, 2023.

The Agency is also proposing to continue to define direct supervision to permit the presence and immediate availability of the supervising practitioner through real-time audio and video interaction telecommunications through December 31, 2024.

The complete 2024 Proposed Rule and Fact Sheet are currently available for review. A complete analysis of the rule is forthcoming. Send your questions to the AASM Health Policy Team at coding@aasm.org.