CMS 2024 Physician Fee Schedule Proposed Rule
CMS has released a fact sheet on their 2024 PFS (Physician Fee Schedule) Proposed Rule. Keep in mind, these proposed rules are up for comment until they publish the final rule sometime this fall. Below are some of the key changes, but by no means, an all-inclusive list. For full details, check out the CMS Fact Sheet on the proposed rule linked above.
Evaluation and Management Services
In the new proposed rule, are some things we have been waiting on, like the Inherent Complexity HCPCS code, first introduced in 2021, but delayed until 2024.
G2211 – Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious, or complex condition.
Likewise, the Shared/Split definition of “substantive portion” is on the table to be tabled, again, in 2024. CMS is proposing that we delay implementation of time-only as the deciding factor for who gets to report the Shared/Split visit.
Caregiver Training
In an effort to support Medicare patients with certain diseases like dementia, CMS is proposing to pay for Caregiver Training Services. When training services are furnished by a physician or an advance care practitioner under an individualized treatment plan or therapy plan of care.
Potential trainers could be:
Advance Practice Providers
- nurse practitioners
- clinical nurse specialists
- certified nurse-midwives
- physician assistants,
- clinical psychologists
Therapists
- physical therapist
- occupational therapist, or
- speech language pathologist
Supervision for Outpatient PT/OT
CMS is proposing a regulatory change to allow for general supervision (rather than direct) of their therapy assistants by PTPPs and OTPPs for remote therapeutic monitoring (RTM) services.
DSMT (Diabetic Self-Management Treatment) performed by RD clarification
CMS intends to clarify in the proposed rule, that an RD or nutrition professional must personally perform MNT services. However, the enrolled RD or nutrition professional, when acting as the DSMT certified provider, may bill for, or on behalf of, the entire DSMT entity, regardless of which professional personally delivers each aspect of the services.
CMS is also proposing to revise their policy by eliminating the regulatory prohibition on providing the full service via telehealth. By doing this, they hope to reach patients that otherwise may not be able to receive DSMT education.
MDPP (Medicare Diabetes Prevention Plan)
Medicare proposes to extend the virtual distance learning option through December 31, 2027. The MDPP must maintain an in-person Centers for Disease Control and Prevention organization code. They also intend to simplify the payment structure to all for FFS (Fee for Service) payments for beneficiary attendance.
Dental and Oral Health Services
Medicare typically does not allow payment for dental services. However, they wrote some provisions into their proposed rule that may allow, under certain circumstances, for dental services to be covered.
They are proposing to codify the previously finalized payment policy for dental services prior to, or during, head and neck cancer treatments, whether primary or metastatic. In addition, CMS is proposing to permit payment for certain dental services inextricably linked to other covered services used to treat cancer — chemotherapy services, Chimeric Antigen Receptor T- (CAR-T) Cell therapy, and the use of high-dose bone modifying agents (antiresorptive therapy). If finalized, this would improve the success of cancer-related treatments and increase access to certain dental care in these particular circumstances.