2024 MPFS proposed rule expands telehealth and dental coverage, steep cuts to conversion factor

CMS is proposing a 3.4% reduction to the Medicare Part B conversion factor in the 2024 Medicare Physician Fee Schedule (MPFS) proposed rule. The agency is also floating expanded telehealth and dental coverage among numerous other changes.

Payment and E/M update

Physician groups have already mobilized to lobby Congress to halt the 3.4% reduction to the conversation factor. In a statement, the American Medical Group Association (AMGA) said the cuts would add pressure to practices that are already struggling financially and could lead to reductions in staffing and services that would negatively affect beneficiaries. The American Medical Association (AMA) called the cuts “almost biblical” in its statement. The AMA, as well as the AMGA and other physician groups, have called on Congress to take action on legislation to address the proposed payment reduction.

For its part, CMS said in the proposed rule that it believes the cuts will be offset by implementation of the separate add-on payment for Healthcare Common Procedure Coding System 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 health care 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).

According to the proposed rule, G2211 would become active on January 1, 2024, and will be assigned a relative value unit (RVU) of 0.33. The agency says it is unsure how utilization of the code will impact budget neutrality, but that it expects the code to be reported with 54% of all office E/M visits, according to Part B News.

Telehealth

CMS is proposing to extend several telehealth flexibilities created during the COVID-19 public health emergency (PHE). Per the Consolidated Appropriations Act of 2023, the agency is proposing to:

• Expand the scope of the originating site to any site in the United States where the beneficiary is located, including the beneficiary’s home
• Expand the definition of telehealth practitioners to include qualified occupational therapists, physical therapists, speech-language pathologists, and audiologists
• Continue payment to rural health clinics and Federally Qualified Health Centers for telehealth services at the rates set during the COVID-19 PHE
• Delay requirement of an in-person visit within six months prior to starting mental health telehealth visits
• Continue coverage and payment of services on the Medicare Telehealth Services List, as of March 2020, until December 31, 2024

Telehealth services provided to beneficiaries in their homes would be paid at the non-facility MPFS rate.

In addition, CMS is proposing a new process for analyzing requests to add services to the Medicare Telehealth Services List, including how to determine whether they should be added permanently.

Dental services

CMS is proposing to allow payment for more dental services, in addition to those approved for 2023, that are linked to certain covered cancer treatments such as chemotherapy and CAR-T. It is also seeking feedback on other dental services that are integral to the clinical success of covered medical services.

NAHRI Advisory Board members Jugna Shah, MPH, CHRI, president and founder of Nimitt Consulting Inc., and Valerie Rinkle, MPA, CHRI, president of Valorize Consulting, spearheaded efforts to provide CMS with data proving that these dental procedures are clinically integral to the success of covered medical services related to certain cancers. CMS’ response demonstrates the agency’s willingness to listen to feedback and apply data, Shah says.

“This is a true and direct advocacy win that impacts patients and it’s one to be joyful about,” Shah says.

Other proposals

CMS is proposing numerous changes related to behavioral health, telehealth, and health-related social needs, as well as changes to various quality and reporting programs. Additionally, the agency is proposing to pause the Appropriate Use Criteria for advanced diagnostic imaging program with no timeframe to recommence and is also proposing to once again delay implementation of the changes to split/shared billing it finalized in the 2022 MPFS final rule.

Looking ahead

Revenue integrity professionals should read the proposed rule carefully and make note of any proposals that could have a direct impact on their organization and job duties. Reach out to colleagues in other departments that may be affected by the proposals to determine the overall impact on the organization.

Consider submitting a comment on the proposed rule to express your support or opposition to various proposals. CMS responds best to data-driven arguments that show how a proposal may help or harm its goal of ensuring Medicare beneficiaries’ well-being and protecting the Medicare Trust Fund. To learn more about how to write effect comments, read NAHRI’s white paper Advocacy in Action: Commenting on Proposed Rules.

Comments on the proposed rule are due September 11.