G2211 Is in the 2024 MPFS Final Rule. Now What?

Because of G2211 and other policy changes, we estimate that the aggregate allowed charges to family medicine will increase by about 2% in 2024. The rule notes an additional increase in allowed charges for those in non-facility settings — also positive for primary care. It’s important to note that the impact on individual physicians will vary based on several factors.

The modest bump is because G2211 will help offset a 3.36% reduction to the conversion factor (the amount Medicare pays per relative value unit) from this year’s factor. This fourth consecutive annual payment cut for physicians is due to the usual statutory suspects: the freeze on Medicare physician payment updates, the budget neutrality mandate and the partial expiration of the most recent conversion factor relief.

David: An increase in allowed charges but also a payment cut?

Meredith: Yes — G2211 means that family physicians will receive an additional payment for many of the office visits they provide, but the lower conversion factor means that payments for every other service are going down.

G2211 is an improvement in the value that Medicare assigns to primary care services. It’s a down payment on greater federal investment in primary care. But any policy improvement made under the MPFS is bound to be undermined by the statutory limitations of the Medicare payment system. That's why we need Congress to act — without jeopardizing G2211.

David: And we see signs of positive activity. Major health care committees are considering legislation right now to provide conversion factor relief and modernize budget neutrality requirements.

Next question: CMS says clinicians cannot bill G2211 alongside modifier 25. What does that mean?

Meredith: Modifier 25 is what a physician claims when performing a procedure or providing some other service (such as the Medicare annual wellness visit) on the same day as an office/outpatient evaluation and management visit. We asked CMS to create an exception for annual wellness visits that would allow clinicians to use both G2211 and modifier 25. This guidance is not reflected in the final rule, but we will continue to make our case. 

David: Everyone should read our summary, but what are a couple of other significant wins for us in the final rule?

Meredith: As we strongly advocated, the rule keeps the MIPS performance threshold (the final MIPS score a participant must achieve to avoid a negative payment adjustment) at 75 for the 2024 performance year, a meaningful reduction from the proposed 82.

The rule notably finalizes new coding and payment for social determinants of health screenings, community health integration services and principal illness navigation services, in line with our advocacy, and increases the value of general behavioral health integration services, which we also supported.

And CMS will pay for telehealth services in 2024 with a place of service code 10 (patient’s home) at the higher non-facility rate, which we called for. 

What’s Next?

The AAFP is intensifying its work to ensure that Congress not only supports G2211’s adoption but also addresses Medicare payment and administrative complexity. Late last month, Academy President Steven Furr, M.D., FAAFP, made this case in person, testifying by invitation before the House Energy and Commerce Health Subcommittee.

“As a family physician who has cared for patients for more than 35 years, I can speak firsthand to how years of increasingly onerous administrative red tape and Medicare’s repeated cuts to physician payment, while already undervaluing primary care, are fueling our primary care workforce shortage,” Furr told legislators.

I encourage you, too, to speak firsthand to Congress. Here’s how.

Add Your Voice (Part 1)

To more comprehensively address inadequate Medicare payment rates, the AAFP has renewed its call on Congress to modernize Medicare’s outdated physician payment system. Family physicians need annual inflationary adjustments and relief from budget neutrality requirements. Our Speak Out tool puts you in touch with your members of Congress so you can join the fight for real, sustainable fixes for Medicare physician payment. Click here today.

Add Your Voice (Part 2)

Another way to ensure that policymakers understand the needs of your practice and your patients is to respond to the Physician Practice Information Survey. Completing it will take about two minutes, and the information you provide — about the time you spend on patient care each week — is extremely important.

Run by the AMA, in tandem with the consulting firm Mathematica, and endorsed by more than 170 medical societies and other health care associations, the survey is gathering data on practice costs, a key element of physician payment. It’s been more than 15 years since this information was last collected, making this new effort vital in the AAFP’s push for accurate payment.

Practices chosen to participate will receive an email (from ppisurvey@mathematica-mpr.com) and a priority mail packet from Mathematica with a link to the survey and supporting information.