The Centers for Medicare & Medicaid Services July 13 released its calendar year 2024 proposed rule for the physician fee schedule. The rule proposes a decrease to the conversion factor by 3.34%, to $32.75 in calendar year 2024, as compared to $33.89 in CY 2023. This reflects the expiration of the 2.5% statutory payment increase for CY 2023; a 1.25% statutory payment increase for 2024; a 0.00% conversion factor update under the Medicare Access and CHIP Reauthorization Act; and a -2.17% budget-neutrality adjustment. 
 
In addition, CMS proposes to delay implementation of its policy to define the substantive portion of a split (or shared) visit based on the amount of time spent by the billing practitioner. Under this policy, if a non-physician practitioner performed at least half of an evaluation and management visit and billed for it, Medicare would only pay 85% of the physician fee schedule rate. 
 
CMS also proposes several provisions to advance access to behavioral health services. For example, it would create a new benefit category for marriage and family therapists and mental health counselors under Part B. In addition, CMS would establish new payment codes for mobile psychotherapy for crisis services. 
For the Quality Payment Program, CMS proposes five new, optional Merit-based Incentive Payment System Value Pathways for reporting beginning in 2024. CMS also proposes to increase both the performance threshold score that MIPS participants must achieve to earn positive payment adjustments, and the quality data completeness threshold. For the Advanced Alternative Payment Model track of the QPP, CMS also proposes to offer Advanced APM Incentive Payments in CY 2025 to those qualifying clinicians. This one-year extension of Advanced APM bonus payments at a reduced rate of 3.5% was required by the Consolidated Appropriations Act of 2023. 
 
Among other changes, CMS proposes to extend several telehealth waivers, such as reimbursement at the non-facility rate for certain telehealth services in the patients’ home; revise the data reporting period and phase-in of payment reductions for clinical laboratory tests under the Clinical Laboratory Fee Schedule; maintain and expand its additional payment for the administration of certain vaccines in the home; and update Medicare Shared Savings Plan quality measurement policies.
 
CMS will accept comments on the proposed rule through Sept. 11. AHA members will receive a Special Bulletin with more details July 14.

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