CMS releases proposed 2024 payment updates for physicians
Today, the Centers for Medicare & Medicaid Services (CMS) released the 2024 Medicare Physician Fee Schedule (PFS) proposed rule, which includes important policy changes to fee-for-service payments and the quality payment program (QPP).
According to CMS, these proposals will lead to -1% payment cut to dermatology. However, CMS stated that this does not take into consideration the impact of the 1.25% increase to the conversion factor provided by the 2023 Consolidated Appropriations Act, which was a result of advocacy from AADA, the AMA, and the medical community. The AADA will continue to evaluate the impact on individual dermatologic codes and total impact could differ depending on practice mix.
Proposed 2024 Medicare Conversion Factor
The proposed 2024 Medicare conversion factor would be reduced by about 3.4% from $33.8872 to $32.7476, resulting in part from a required budget neutrality adjustment.
The AADA, alongside the entire house of medicine, has succeeded in mitigating payment cuts for the last several years, but physicians need Congress to act to stabilize the Medicare payment system. The AADA has urged Congress to provide a permanent solution, and it is a top advocacy priority. AADA members can contact their representatives and urge them to provide an inflation-based increase in Medicare payments in 2024 and future years by cosponsoring H.R. 2474, the “Strengthening Medicare for Patients and Providers Act.”
Other proposed changes announced by the CMS included:
E/M Complexity Add-on Code (HCPCS Code G2211)
CMS proposed HCPCS Code G2211 in 2024, which will have a significant impact on budget neutrality. In the 2021 Medicare PFS Final Rule, the agency finalized HCPCS G2211, resulting in a redistribution of $3 billion. In December 2020, the AADA, and the house of medicine, successfully urged Congress to delay the implementation of the G2211 add-on code for three years.
Telemedicine Polices
CMS proposed several telehealth-related provisions required under the 2023 Consolidated Appropriations Act, including the temporary expansion of the scope of telehealth originating sites for services furnished via telehealth to include any site in the United States where the beneficiary is located at the time of the telehealth service, including an individual’s home, through December 31, 2024, as required by Congress.
Drugs and Biologicals Which are Not Usually Self-Administered by the Patient, and
Complex Drug Administration Coding
As a direct result of the AADA’s and other specialty societies advocacy efforts, CMS is soliciting comments from stakeholders regarding their policies on excluding coverage for certain drugs under Part B that are usually self-administered by the patient. The agency is seeking comments on coding and payment policies for complex non-chemotherapeutic drugs. In December 2022, the AADA along with other specialty societies, met with CMS to promote coding and payment consistency and patient access to infusion services.
Changes to the QPP
CMS proposed to increase the performance threshold in the QPP from 75 to 82 points for the 2024 Merit-Based Incentive Payment System (MIPS) performance period/2026 MIPS payment year. CMS proposed five new Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) to be available for the 2024 performance year, none of which impact dermatology. The agency also proposed to remove the topped-out MIPS Measure 138 Melanoma Coordination of Care.
The AADA staff is reviewing the almost 2,000+ page proposed rule and will prepare comments to CMS by the September 2023 deadline. Additional detailed analysis of the proposals will be featured in upcoming issues of DermWorld Weekly and on AAD.org.
We encourage members to register for the 2023 AADA Legislative Conference, providing an opportunity to engage with Members of Congress, voice concerns about the proposed payment cuts, and urge Congress to take immediate action to stop the cuts affecting dermatology practices while finding a lasting solution for Medicare payments to ensure uninterrupted patient care.
Additional Resources
