Comments are in on CMS' proposed physician fee schedule: 5 things to know

Input on CMS' proposed physician fee schedule for 2024 was due last week — and among comments from providers, private insurers and other healthcare players, there were a few common themes.

Here is a breakdown of five things to know from responses to the proposed rule, as laid out by McDermott+Consulting on Sept. 15 in JDSupra:

1. Provider groups were universally concerned and disappointed with the proposed 3.3 percent cut to the physician fee schedule conversion factor — especially considering inflation is expected to increase 4.5 percent next year.

2. Most provider groups and telehealth stakeholders expressed support for continuing telehealth flexibilities proposed by CMS, including keeping telehealth codes that were added to the Medicare Telehealth list during the COVID-19 public health emergency through 2024, extending direct supervision waivers and allowing providers to bill at the highest non-facility rate for services while patients are located at their homes.

3. Commenters expressed concern over the direction CMS is taking the Quality Payment Program, including the Merit-based Incentive Payment System and Advanced Alternative Payment Models. CMS proposed an increase in the Merit-based performance threshold from 75 points to 82 in 2024, saying it is too sharp of an increase.

4. CMS proposed changes to who is a qualified Advanced Alternative Payment Model participant, proposing to change from judging the percentage of payments provided from an overall group or practice level to the individual level. Respondents said they believe this change will make it more difficult for specialists to meet payment thresholds. 

5. There was near-universal approval of establishing new codes and payments for community health integration services, social determinants of health risk assessments, and principal illness navigation services provided by social workers, community health workers and other personnel.

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