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Last week, CMS released the CY 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule, accompanied by a press release, a physician fee schedule fact sheet, and a QPP fact sheet. CMS estimates the CY 2024 proposed MPFS conversion factor to be $32.7476, a decrease of approximately 3.34% ($1.1396) from today’s conversion factor of $33.8872. The impact of CMS’ polices on rheumatology is +2.0%, primarily due to the implementation of a revised complex care add-on code (G2211). However, when coupled with the lower 1.25% payment update provided under the Consolidated Appropriations Act, 2023, the impact is closer to +0.75% (as a reminder, Congress provided a 2.5% update in CY 2023).
Due to strong CSRO advocacy, CMS announced they are seeking feedback on challenges with drug administration services, including problematic “down coding” of complex drug administrations and the Self-Administered Drug (SAD) List criteria. The rule also proposes several new codes to improve health equity and makes revisions to Medicare’s telehealth policies following the end of the COVID-19 public health emergency. Further, CMS is proposing additional policies to implement its “discarded drug” policy, including a modification to the JW and JZ modifier policy. Specifically, CMS proposes to require that drugs separately payable under Part B from single-dose containers that are furnished by a supplier who is not administering the drug be billed with the JZ modifier. Finally, CMS proposes changes to the practice expense values for certain neuromuscular ultrasound codes, but no changes to the work values.
An overview of these and other notable policies in the rule will be presented at CSRO's Advocacy Conference next month in Austin – registration closes this Monday, and details are included above and on our website.
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