The Centers for Medicare and Medicaid Services (CMS) released the 2024 Medicare Physician Fee Schedule (PFS) final rule and the 2024 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) final rule on Nov. 2. Of note, the 2024 PFS conversion factor is $32.7442, reduced 3.37% from $33.8872 in 2023. Overall, PFS reimbursement for cardiovascular services is projected to remain flat compared with 2023, with changes to policies and individual services roughly balancing out. Individuals and groups will see different impacts depending on patient populations and services offered. 

Initial highlights from the final rule include:

• Appropriate Use Criteria (AUC) Mandate Program: CMS finalized its proposal to pause implementation efforts of the AUC program, rescind current regulations and cease educational and operational testing. The agency says it will continue seeking away to implement the program. Any new process will be proposed in future rulemaking.
• Split/Shared Billing Changes: CMS finalized a change in its definition of "substantive portion" to match that of the revised CPT E/M definition which is "more than half of the total time spent by the physician and NPP performing the split (or shared) visit, or a substantive part of the medical decision making (MDM) as defined by CPT." This effectively nullifies the prior, postponed policy that would have eliminated MDM as a deciding factor.
• G2211 Office/Outpatient E/M Visit Complexity Add-On HCPCS Code: CMS finalized its proposal to make this code "active" effective Jan. 1, 2024. Despite ACC's and others’ comments that the code was vaguely defined and the estimated utilization was too high, no changes were made to the utilization assumptions. This drives a portion of the budget neutrality conversion factor reduction.
• Updated Code Values for New/Revised Services: Final work RVUs and practice expense inputs are included in the rule that will determine payment rates in 2024 in various addenda tables. An updated calculator tool will be available soon.
• Telehealth Home Address Enrollment: Through CY 2024, CMS will continue to permit a distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home. They will also consider this issue further for future rulemaking.
• QPP, MIPS, MVP, MSSP: The MIPS performance threshold is updated – leaving it at 75 points rather than increasing to 82 points – and the rule further refines MVPs and continues policies to align MSSP with MIPS.

The 2024 OPPS final rule sets a 3.1% increase to OPPS payment rates to hospitals and ASCs that meet relevant quality reporting requirements, reflecting a market basket update of 3.3% reduced by a productivity adjustment of 0.2%. No changes were made to cardiovascular services on the Inpatient-Only List and the ASC Covered Procedures List, and ambulatory payment classification payments for cardiovascular care are mostly stable. CMS also finalized changes it believes will strengthen hospital price transparency processes.

ACC Advocacy staff will provide a more detailed breakdown of the final rules in the coming days. Additional information on the rule can be found in the Medicare PFS Press Release, Medicare PFS Fact Sheet, Medicare Shared Savings Program Fact Sheet and the QPP Fact Sheet. OPPS resources include an OPPS Press Release, OPPS Fact Sheet and Transparency Fact Sheet. Look for updated information on ACC.org/Advocacy and in upcoming issues of The Advocate newsletter.

Keywords: ACC Advocacy, Medicare, Centers for Medicare and Medicaid Services, U.S., Outpatients, Healthcare Common Procedure Coding System, Fee Schedules, Physicians, Policy, Telemedicine, Hospitals

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