Heart of Health Policy | Highlights From Final 2024 Medicare PFS and OPPS Rules
The final 2024 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) rules are out, setting payment rates for the new year.
Under the Medicare PFS, the conversion factor is $32.7442, down from 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.
The final Medicare PFS also addresses Appropriate Use Criteria (AUC), split-shared billing rules, telemedicine flexibilities extensions, the G2211 outpatient/office E/M visit complexity add-on HCPCS code, new and revised CPT code valuations, and a new Heart Failure Cost Measure along with numerous updates to the Medicare Shared Savings Program (MSSP), Merit Based Incentive Payment System (MIPS) and Quality Payment Program (QPP).
On the OPPS and ASC front, the final rule implements a 3.1% increase to payment rates that reflect 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.
The ACC Advocacy Team has developed overviews of both rules, calling out the major cardiovascular-related provisions.
Medicare PFS highlights, include:
- Indefinitely pauses implementation of the AUC program and rescinds current program regulations.
- Walks back the Centers for Medicare and Medicaid Services' (CMS) prior split/shared billing plan to require the clinician who spent the most time with the patient to report the service. The agency instead finalized a change in its definition of "substantive portion" of a split/shared service to match that of the revised CPT E/M definition.
- Includes final work relative value units (RVUs) and practice expense inputs for new and revised codes, which will determine payment rates in 2024.
- Finalizes the CMS proposal to change the status of the G2211 Office/Outpatient E/M Visit Complexity Add-on HCPCS code to "active" effective Jan. 1, 2024. Despite comments from ACC and others warning that the code was vaguely defined and that the estimated utilization was too high, no changes were made to the utilization assumptions or code definition. This change drives a significant portion of the budget neutrality conversion factor reduction.
- Allows advanced practice practitioners, starting Jan. 1, 2024 to supervise cardiac rehabilitation, intensive cardiac rehabilitation and pulmonary rehabilitation.
- Temporarily expands some telehealth flexibilities until Dec. 31, 2024, including allowing a distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.
- Adds five new MIPS Value Pathways (MVPs) to be available with the 2024 performance year, along with revisions to all previously finalized MVPs, including the Advancing Care for Heart Disease MVP.
OPPS and ASC final rule highlights include:
- Cardiac Positron Emission Tomography (PET)/Computed Tomography (CT) Studies
- APC Complexity Adjustments
- Supervision by NPs, PAs, and CNSs of Cardiac Rehabilitation (CR), Intensive Cardiac Rehabilitation (ICR) and Pulmonary Rehabilitation (PR) Services Furnished to Outpatients
- Expiration of Transitional Pass-Through Payment for Coronary Intravascular Lithotripsy
- Cardiac Ablation Services Not Added to ASC Covered Procedures List (CPL)
- Inpatient-Only List (IPO)
- ASC CPL
- Excessive Radiation Electronic Clinical Quality Measure (eCQM)
- Hospital Outpatient/ASC Facility Volume Data on Selected Outpatient Surgical Procedures
- Hospital Price Transparency
Click here for OPPS Rule details.
Estimate the Impact
Download the ACC's new PFS Final Rule Calculator to help with estimating the potential impact of changes to practices. Click here for more details on these and other cardiovascular-related Medicare PFS provisions.
Advocating For Long Term Payment Solutions
The ACC, along with other medical societies, has aligned with the American Medical Association on a set of principles to guide advocacy efforts on Medicare physician payment reform. The ACC strongly supports the Strengthening Medicare for Patients and Providers Act (H.R. 2474), which would provide a permanent, annual update equal to the increase in the Medicare Economic Index, allowing physicians to invest in their practices and implement new strategies to provide high-value care.
The ACC will also continue its work to explore approaches that promote health care system stability and foster a successful, widespread transition to value-based care, reflecting the needs of cardiovascular patients and clinicians in every setting.
Find More Answers at the CV Summit
Take advantage of ACC's Cardiovascular Summit, taking place Feb. 1-3 in Washington, DC, to dive deeper into 2024 provisions and what you need to know. Advance registration ends Dec. 12.
Also, don't forget to take advantage of group discounts when you take your whole team. Click here for the agenda and to register.
Looking for additional resources to help with implementing coding changes and more? Visit MedAxiom.com to access webinars, podcasts and other tools to help navigate the Medicare PFS.
Physician Practice Information Surveys Second Wave Coming Soon
The American Medical Association has contracted with Mathematica to undertake a national survey, collecting representative data on physician practice expenses. Responses from randomly selected physician practices and individual physicians will be used to inform physician payment advocacy. This is an opportunity to communicate financial information to policymakers, including members of Congress and government agencies.
Please monitor your email for important surveys from Mathematica on practice costs and work hours. Surveys must be completed thoroughly and accurately, since results will be used to adjust practice payments.
Click here to learn more about the survey and what to expect.
Keywords: ACC Publications, Cardiology Magazine, ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Healthcare Common Procedure Coding System, Medicare, Hospitals, Prospective Payment System
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