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We previously highlighted the release of the calendar year (CY) 2024 Medicare physician fee schedule (PFS) proposed rule, which includes a number of provisions that will impact our specialty. Most notably, the Agency estimates a drop to the conversion factor by approximately -3.34%, which is largely due to adjustments to maintain budget neutrality and the lower payment update provided by Congress in the Consolidated Appropriations Act, 2023.
Despite the cuts, CMS anticipates a small, upward shift in funding for rheumatology services due to a new “complexity add-on code” that will provide additional dollars for the longitudinal care we provide our patients with complex conditions.
CSRO continues to engage with CMS about its proposed policies, including developing a response to their Request for Information (which was included in this rule at the urging of CSRO and our coalition partners) on the challenges rheumatology practices tell us they are facing daily as a result of drug administration service “down coding” and inappropriate placement of key rheumatologic medications on the “SAD List” by Medicare Administrative Contractors (MACs).
As a direct result of CSRO’s advocacy, CMS also proposes to adopt IA_BE_ 24: Financial Navigation Program or IA_BE_25: Drug Cost Transparency – two important and meaningful Improvement Activities (IA) – as part of the Advancing Rheumatology Patient Care MIPS Value Pathway (MVP). While the cost measurement in this MVP remains flawed, we are pleased that CMS agreed with CSRO’s recommendation to incorporate the activities private rheumatology practices must undertake to help patients navigate complex processes to make their medications more affordable and accessible.
Advocating on behalf of private practicing rheumatologists and their patients is the heart of CSRO's mission. We look forward to gathering at our annual Advocacy Conference next week in Austin, TX, where we will share more about the impact of the proposed CY24 PFS on rheumatology and other issues of interest!
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