2024 MPFS final rule includes cuts to conversion factor, implementation of new add-on visit code
The conversion factor cuts that CMS floated earlier in the year are now confirmed—and heightened. Part B providers will have to prepare for a net 3.4% payment decrease across services in 2024, according to the 2024 Medicare Physician Fee Schedule (MPFS) final rule released November 2.
Other provisions of the final rule cover add-on visit codes, quality programs, and more.
CMS finalized a 3.39% cut to the conversion factor, slightly higher than the 3.36% it proposed. While the conversion factor decrease will suppress the universe of Part B allowed charges in 2024, not all individual services will be affected the same. Final payment rates will vary depending on other inputs, such as relative value units (RVU).
Add-on visit-complexity code
CMS finalized activation of Healthcare Common Procedure Coding System (HCPCS) code G2211 (visit complexity inherent to evaluation and management [E/M] associated with medical care services that serve as the continuing focal point for all needed healthcare services and/or with medical care services that are part of ongoing care related to a patient's single, serious condition or a complex condition), effective January 1, 2024.
CMS lowered its initial estimate of billing frequency for the add-on code, projecting that it will be reported on 38% of all office visit codes at the outset. That number could rise to 54% of office visits once the provider community grows more comfortable with its use, the agency says.
Key to the code’s correct usage is the manner of the relationship between the provider and patient. “We clarify that it is the relationship between the patient and the practitioner that is the determining factor of when the add-on code should be billed,” the agency states in the final rule.
CMS says that, under the current fee structure, cognitive work associated with providing longitudinal care to patients is underpaid, and that G2211 is intended to make up for part of the shortage. The agency offers an example of when – and why – the code should be used.
“For example, a patient has a primary care practitioner that is the continuing focal point for all healthcare services, and the patient sees this practitioner to be evaluated for sinus congestion," the final rule states. “The inherent complexity that this code (G2211) captures is not in the clinical condition itself—sinus congestion—but rather the cognitive load of the continued responsibility of being the focal point for all needed services for this patient.”
CMS accepted a work RVU figure of 0.33 for the code. As proposed, the add-on code will not be accepted with an E/M service reported with modifier -25 (significant, separately identifiable E/M service).
CMS will adopt the American Medical Association’s definition of the substantive portion for a split or shared visit. “Specifically, for CY 2024, for purposes of Medicare billing for split (or shared) services, the definition of “substantive portion” means more than half of the total time spent by the physician and nonphysician practitioner performing the split (or shared) visit, or a substantive part of the medical decision-making [MDM] as defined by CPT,” the agency announced in the final rule. Split or shared critical care services will continue to follow Medicare’s time-based rules.
Starting in 2024, the pneumococcal, influenza, and hepatitis B vaccines, when provided in the home, will be reimbursed the same as the COVID-19 vaccine: $40.
The final rule also covers numerous changes to therapy code valuations, Shared Savings, quality programs, and more.
Revenue integrity professionals should read the final rule carefully. Pay particular attention to the sections that affect your job duties, your department, or the services your organization offers. Make a note of effective dates and compliance deadlines and ensure plans are in place to update systems and processes as necessary. Update internal audit plans to review these changes in 2024.
Discuss the final rule with colleagues in other departments and coordinate education, particularly for coding and documentation.
More information on the 2024 MPFS final rule will be featured in the January 2024 issue of the NAHRI Journal. Experts will also analyze provisions of the 2024 MPFS final rule in the December 14 webinar “Unpack the 2024 OPPS Final Rule,” presented by Kimberly A. Hoy, JD, CPC, director of Medicare and compliance for HCPro; Teri Rice, MSN, MHA, MBA, RN, CHC, lead instructor for HCPro’s Medicare Boot Camp—Critical Access Hospital Version and Rural Health Clinic Version and an instructor for the Medicare Boot Camp—Utilization Review Version; and Amy Inch, COTA, CPC, CPMA, HCPro’s Medicare Boot Camp—Physician Services Version and Denials and Appeals version.
Editor's note: A version of this article originally appeared on Part B News.