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Final 2024 Medicare PFS Boosts Rheumatology Pool by 2%; CSRO Urges Congress to Advance Physician Pay Reforms

Posted: November 10, 2023

On November 2, CMS released the Calendar Year (CY) 2024 Medicare Physician Fee Schedule Final Rule, announcing a conversion factor of $32.7442 – down 3.37% or $1.15 from the CY 2023 MPFS conversion factor of $33.89. The CY 2024 MPFS conversion factor reflects the following:

  • the 0.00% update adjustment factor as established in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA);
  • and a 1.25% update provided under the Consolidated Appropriations Act, 2023 (CAA, 2023);
  • a budget neutrality adjustment of -2.18%, primarily due to the implementation of the revised complex care add-on code (G2211).

According to the CMS estimated impact on total allowed charges by specialty (Table 118), Rheumatology will see an overall payment boost of 2%, which stems from the anticipated utilization of G2211 by the specialty. Payment rates for rheumatology services can be calculated using the relative values in Addendum B.

Despite a generally positive outcome to the overall rheumatology pool, CSRO continues to advocate that lawmakers address the reduced conversion factor and permanently incorporate a measure of inflation in annual update calculation, among other reforms.

Following its request for information titled “Drugs and Biologicals which are Not Usually Self-Administered by the Patient, and Complex Drug Administration Coding,” CMS responded to feedback from the CSRO and a multi-provider workgroup that asked CMS to revisit Medicare rules on the Self-Administered Drug Exclusion List (aka SAD List) and “down coding” of complex drug administration services when key rheumatology medications are used. On both issues, CMS said it looks forward to continued discussions with interested parties as it works toward potentially developing changes to these policies, with the potential for future rulemaking.

Regarding neuromuscular ultrasound, CMS finalized direct practice expense refinements for CPT codes 76881, 76882, and 76883, and shared that the American Medical Association (AMA) Relative Value Scale Update Committee (RUC) “plans to review the practice expense for CPT codes 76881, 76882, and 76883 with additional data according to their new technology process at a future RUC meeting.”

The rule also implements of several telehealth-related provisions of the Consolidated Appropriations Act, 2023 (CAA, 2023), 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, and the continued coverage and payment of telehealth services included on the Medicare Telehealth Services List (as of March 15, 2020) until December 31, 2024. Related, CMS finalized the continued definition of direct supervision to permit the presence and immediate availability of the supervising practitioner through real-time audio and video interactive telecommunications through December 31, 2024.

With regard to the Quality Payment Program (QPP), CMS retained the MIPS performance threshold at 75 (rather than increasing to 82) and the category weights for 2024 performance year/2026 payment year will be:

  • 30% for the Quality performance category.
  • 30% for the Cost performance category.
  • 15% for the Improvement Activities performance category.
  • 25% for the Promoting Interoperability performance category.

The Advancing Rheumatology Patient Care MIPS Value Pathway was also updated to include IA_BE_24: Financial Navigation Program and IA_BE_25: Drug Cost Transparency, based on CSRO and other stakeholder comments.

Fact sheets on the rule can be found here.

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