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What ASCs Need to Know About the 2024 Medicare Physician Fee Schedule Proposed Rule

By Kelsey Moore, Director of Regulatory Affairs, nimble solutions

It’s here: The Centers for Medicare and Medicaid (CMS) issued their 2024 proposed policy changes to the Physician Fee Schedule (PFS) for Medicare payments and Medicare Part B issues.  

This blog post gives an overview of the proposed CY 2024 PFS rule and the key factors that will potentially affect Ambulatory Surgery Centers (ASCs) in 2024 and beyond.

What is the Physician Fee Schedule (PFS)?

Since 1992, Medicare has utilized the Physician Fee Schedule (PFS) as the basis for reimbursing physicians and other billing professionals for their services. These services are provided in various settings, such as physician offices, hospitals, ambulatory surgical centers (ASCs), skilled nursing facilities, and patients’ homes.  

The PFS payment rates take into account the resources involved in delivering each service and are determined through relative value units (RVUs) for work, practice expense, and malpractice expense, along with a conversion factor.  

Separate payments may be made for the professional and technical components of certain services, depending on the nature of the service. Additionally, geographic adjusters are applied to account for cost variations in different regions. Ultimately, payment rates are calculated to include an overall payment update specified by statute. 

Conversion Factor Adjustment

The proposed CY 2024 PFS conversion factor is $32.75, a decrease of $1.14 (or 3.34%) from the current CY 2023 conversion factor of $33.89. 

This decrease could have financial implications for ASCs, as it directly affects the reimbursement rates for various services. 

In response to this proposed change, ASCs should closely analyze their revenue and expenses to ensure continued financial viability while providing quality patient care. 

Add-on Payment for HCPCs Code G2211

Beginning January 1, 2024, CMS is proposing to implement a separate add-on payment for healthcare common procedure coding system (HCPCS) code G2211, which will apply to outpatient office visits.  

This add-on payment recognizes the inherent costs clinicians may incur when providing longitudinal treatment for a patient’s single, serious, or complex chronic condition. 

For ASCs that frequently treat patients with chronic conditions, this additional payment could be beneficial. However, ASCs must ensure proper documentation and coding to receive the add-on payment accurately. 

Inclusion of Health and Well-Being Coaching Services in Medicare Telehealth Services List

CMS is proposing to include health and well-being coaching services in the Medicare Telehealth Services List on a temporary basis for CY 2024.  This change highlights the increasing importance of telehealth and its potential to improve patient outcomes. 

ASCs may find this expansion of telehealth services as an opportunity to reach patients in remote areas or those who face difficulties in accessing in-person care. However, ASCs need to assess their telehealth capabilities and compliance with relevant regulations to leverage this service effectively. 

Permanent Inclusion of Social Determinants of Health Risk Assessments in Medicare Telehealth Services

Another notable proposal by CMS is the permanent inclusion of Social Determinants of Health (SDOH) Risk Assessments in the Medicare Telehealth Services List.  

Telehealth services, both audiovisual and audio-only, have enabled individuals in rural and underserved areas to have improved access to care. This move aims to address health disparities among Medicare beneficiaries and may lead to more targeted and effective care for patients.

Payment for Home-Based Telehealth Services

CMS is proposing that, starting in CY 2024, telehealth services provided to patients in their homes be paid at the non-facility PFS rate. This measure aims to protect access to mental health and other telehealth services by aligning with telehealth-related flexibilities extended via the CAA, 2023. 

For ASCs considering expanding into home-based telehealth services, this change presents an opportunity to reach a broader patient population. However, it also requires careful planning to ensure compliance with regulations and maintain the quality of care provided. 

Delay in Split E/M Visit Billing Changes

The proposed rule includes a delay in the implementation of Split (or shared) Evaluation and Management (E/M) visit billing changes. The delay could give ASCs additional time to prepare for these changes and adapt their billing and coding practices accordingly.

Final Takeaways on the Proposed 2024 Physician Fee Schedule

The proposed CY 2024 PFS rule includes adjustments to the conversion factor, the introduction of add-on payments, expanded telehealth services, and more. By understanding these changes and their potential impact, surgeons and their ASCs can position themselves to provide high-quality care while navigating the evolving healthcare reimbursement landscape.  

While considering these updates, it’s important to note that the information presented in this blog is based on CMS’s proposed CY 2024 Physician Fee Schedule.  As the rulemaking process is ongoing, it is essential to monitor updates and official publications from CMS for any changes or finalization of the proposed rule. 

For a more detailed overview, access the CMS fact sheet on the 2024 Medicare Physician Fee Schedule Proposed Rule here 

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